a

GAO

United States Government Accountability Office

Report to the Ranking Minority Member, 

Committee on Banking, Housing, and 

Urban Affairs, U.S. Senate

November 2005 TRANSPORTATION 

SERVICES

Better Dissemination 

and Oversight of 

DOT’s Guidance Could 

Lead to Improved 

Access for Limited 

English-Proficient 

Populations

GAO-06-52
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

November 2005

TRANSPORTATION SERVICES 

Better Dissemination and Oversight of 

DOT's Guidance Could Lead to Improved 

Access for Limited English-Proficient 

Populations 

Highlights of GAO-06-52, a report to the 

Ranking Minority Member, Committee on 

Banking, Housing, and Urban Affairs, U.S. 

Senate 

More than 10 million people in the

United States are of limited English 

proficiency (LEP), in that they do

not speak English at all or do not 

speak English well. These persons 

tend to rely on public transit more

than English speakers. Executive

Order 13166 directs federal

agencies to develop guidance for 

their grantees on making their 

services accessible to LEP persons.

The Department of Transportation

(DOT) issued its guidance in 2001, 

with revised guidance pending

issuance. This report reviews (1) 

the language access services transit 

agencies and metropolitan planning

organizations have provided, and

the effects and costs of these 

services; (2) how DOT assists its 

grantees in providing language

access services; and (3) how DOT

monitors its grantees’ provision of

these services. 

What GAO Recommends

GAO recommends that the 

Secretary of DOT (1) ensure that

DOT’s revised LEP guidance is

directly distributed to all DOT 

grantees; (2) consider providing 

additional assistance to grantees in

providing language access; and (3) 

more fully incorporate the revised 

guidance in current review 

processes, and establish consistent 

norms for what constitutes a 

language access deficiency.

DOT generally concurred with the 

findings and recommendations in

this report. Examples of Translated Signs in Orange County, California

Transit agencies and metropolitan planning organizations provide a variety 

of language access services, predominantly in Spanish, but the effects and 

costs of these services are largely unknown. Types of services provided 

included, among other things, translated brochures and signs; multilingual 

telephone lines; bilingual drivers; and interpreters at public meetings. 

However, few agencies we visited had conducted an assessment of the 

language needs in their service areas, or had conducted an evaluation of 

their language access efforts. As a result, it is unclear whether agencies’ 

efforts are comprehensive enough to meet the needs of LEP persons, and 

community groups in the areas we visited saw important gaps in agencies’ 

services. In addition, although those costs are largely unknown, several 

agencies saw providing language access as a cost of doing business, not as 

an additional cost. However, if efforts were to be expanded to include 

additional services or languages, agency officials told us that costs could 

become prohibitive. 

DOT assists grantees in providing language access through its guidance and 

other activities, but DOT has made limited efforts to ensure that grantees are

aware of the available assistance, which was not often accessed by the 

agencies we visited. This assistance includes DOT’s guidance—which 

provides a five-step framework for how to provide meaningful language 

access—as well as workshops and peer-exchange programs that include 

language access practices, and training courses that touch on language 

issues. DOT also participates in a federal LEP clearinghouse, www.lep.gov. 

However, few agencies we visited had accessed these resources. Several

local officials stated that easily accessible training and assistance specific to

language access and examples of how to implement DOT’s guidance could 

help them more effectively provide access to LEP populations. 

Transit agencies’ and metropolitan planning organizations’ provision of 

language access services are monitored through in-depth civil rights 

compliance reviews and two broader reviews—triennial reviews of 

transit agencies and planning certification reviews. However, these 

reviews do not have consistent criteria for determining whether an agency is 

deficient in providing such services. Furthermore, these reviews do not fully 

reflect Executive Order 13166 or DOT’s guidance. Without thorough and 

consistent monitoring that takes into account the guidance, local agencies’ 

language access activities will likely remain varied and inconsistent.

www.gao.gov/cgi-bin/getrpt?GAO-06-52.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Kate Siggerud 

at (202) 512-2834 or siggerudk@gao.gov. 

Translated report summaries are available in 

Spanish, Chinese, Vietnamese, and Korean 

at www.gao.gov/special.pubs/translations. 
Page i GAO-06-52 Language Access to Transportation Services

Contents

Letter 1

Results in Brief 6

Background 9

Several Types of Language Access Services Are Provided, but Little 

Is Known about the Effects and Costs of Services 12

DOT Assists Grantees on Language Access Services through Its 

Guidance and Other Activities, but These Resources Are Not 

Often Accessed by Local Agencies 38

Three Review Processes Provide Limited Monitoring of Language 

Access Activities, and Criteria for Finding a Deficiency Are 

Inconsistent 47

Conclusions 54

Recommendations for Executive Action 56

Agency Comments 57

Appendixes

Appendix I: Scope and Methodology 59

Appendix II: Resources Available on Providing Language Access for 

Transportation Services 67

Provision of Language Access Services 67

Community Involvement in Transportation Planning 69

Appendix III: GAO Contact and Staff Acknowledgments 70

Tables Table 1: FTA and FHWA Reviews 47

Table 2: Language Access Deficiencies Found through Title VI 

Compliance Reviews 49

Table 3: Results of the Pilot LEP Review of the Brownsville Urban 

System in Texas 51

Table 4: Census Data on Language Ability and Transit Use for Seven 

Site Visit Locations 59

Table 5: Transit Agencies, MPOs, and Community and Advocacy 

Groups Interviewed 62

Figures Figure 1: LEP Population in 2000, by County 2

Figure 2: Percentage Growth of LEP Populations between 1990 and 

2000, by County 3
Contents

Page ii GAO-06-52 Language Access to Transportation Services

Figure 3: Percentage of Transit Agencies and MPOs We Visited That 

Make These Types of Language Access Services Available 

in at Least Spanish 14

Figure 4: English and Spanish Versions of the Los Angeles County 

Metropolitan Transportation Authority’s Rider’s Guide 17

Figure 5: Seven-Language Bus Stop Sign in Oakland, California 20

Figure 6: Meeting Notice Posted on a Bus in San Francisco, 

California, in English and Chinese 22

Figure 7: Posters in Orange County, California, in English and 

Spanish 23

Figure 8: Golden Gate Transit’s Spanish Phrase Guide for 

Drivers 25

Figure 9: Spanish Version of the Ozark Regional Transit’s Web Site 

Home Page 29

Abbreviations

DOJ Department of Justice

DOT Department of Transportation

FHWA Federal Highway Administration

FTA Federal Transit Administration

LEP limited English proficiency

MPO metropolitan planning organization

NHI National Highway Institute

NTI National Transit Institute

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Page 1 GAO-06-52 Language Access to Transportation Services

United States Government Accountability Office

Washington, D.C. 20548

A

November 2, 2005 Letr

The Honorable Paul S. Sarbanes

Ranking Minority Member

Committee on Banking, Housing, and Urban Affairs

United States Senate

Dear Senator Sarbanes:

The United States has a highly diverse population representing cultures 

from all over the world. English is not the primary language of many people 

living in the United States, and significant numbers have little or no English 

skills. According to the 2000 U.S. Census, more than 10 million people 

reported that they do not speak English at all, or do not speak English well. 

These persons of limited English proficiency (LEP), like English speakers, 

may depend on government for a wide range of services, including public 

transportation. For many LEP persons, public transit is a key means of 

achieving mobility. According to the 2000 Census, more than 11 percent of 

LEP persons aged 16 years and over reported using public transit as their 

primary means of transportation to work, compared with about 4 percent 

of English speakers. 

The number of persons reporting that they do not speak English at all or do 

not speak English well grew by 65 percent from 1990 to 2000. As figures 1 

and 2 demonstrate, while LEP populations tend to be largest in counties in 

border and coastal states, the largest growth in these populations is 

occurring in the Midwest and the South. Among limited English speakers, 

Spanish is the language most frequently spoken, followed by Chinese 

(Cantonese or Mandarin), Vietnamese, and Korean. 
Page 2 GAO-06-52 Language Access to Transportation Services

Figure 1: LEP Population in 2000, by County

LEP County Population (county)

20,000--1,400,000 (89)

1,000--20,000 (547)

1--1,000 (2,475)

0 (28)

All others (80)

Source: GAO analysis of U.S. Census Bureau data.
Page 3 GAO-06-52 Language Access to Transportation Services

Figure 2: Percentage Growth of LEP Populations between 1990 and 2000, by County

Title VI of the Civil Rights Act of 19641 prohibits recipients of federal 

financial assistance from discriminating on the basis of race, color, or 

national origin. Executive Order 13166, which was signed by President 

Source: GAO analysis of U.S. Census Bureau data.

Percentage of LEP

Growth (county)

1,000--16,400 (92)

200--1,000 (633)

-100--200 (2,355)

Cannot calculate (59)

All others (80)

1

42 U.S.C. § 2000d et seq.
Page 4 GAO-06-52 Language Access to Transportation Services

Clinton in 2000,2 sought to clarify the responsibilities of federal agencies 

and their grant recipients under Title VI to make their programs and 

activities accessible to LEP populations, and it required federal agencies to 

issue guidance to their funding recipients to avoid discriminating on the 

basis of national origin. The Department of Transportation (DOT) issued 

guidance in 2001, which discusses strategies for providing services to LEP 

persons, based on guidelines put forth by the Department of Justice (DOJ). 

This guidance, while in effect for grantees since 2001, was subsequently 

revised by DOT after public comments were received on it. The revised 

guidance was approved by DOJ on August 25, 2005, and DOT is preparing 

to publish and release this revised guidance. 

Advocacy organizations and others have raised concerns over the extent to 

which DOT’s guidance to its funding recipients is being implemented. A 

lack of English skills has the potential to hinder many LEP persons from 

fully utilizing public transit services and meaningfully participating in the 

transportation planning process. The inability to effectively access public 

transit services can result in an array of harmful consequences for LEP 

persons, including a reduction in employment opportunities, increased 

difficulty in accessing other needed services, the perpetuation of social 

isolation, and the diminishment of overall quality of life. In light of these 

issues, this report discusses (1) the types of language access services that 

transit agencies and metropolitan planning organizations (MPO) have 

provided to the LEP populations in their service areas, and the effects and 

costs of these services; (2) how DOT and its modal administrations assist 

grantees in providing language access services for LEP populations; and (3) 

how DOT and the responsible modal administrations monitor grantees’ 

provision of language access services for LEP populations. 

To determine the types of language access services that transit agencies 

and MPOs provided to LEP populations, we visited seven metropolitan 

statistical areas3

 in Arkansas, California, Illinois, North Carolina, and 

2

Executive Order 13166, “Improving Access to Services for Persons with Limited English 

Proficiency.” 65 Fed. Reg. 50121 (Aug. 16, 2000).

3

A metropolitan statistical area is a core area containing a substantial population nucleus, 

together with adjacent communities, having a high degree of social and economic 

integration with that core. Metropolitan statistical areas comprise one or more entire 

counties. The Office of Management and Budget defines metropolitan statistical areas for 

the purposes of collecting, tabulating, and publishing federal data. Metropolitan statistical 

area definitions result from applying published standards to U.S. Census Bureau data.
Page 5 GAO-06-52 Language Access to Transportation Services

Texas.4 We used census data to select these site visit locations on the basis 

of the size, proportion, and growth of the LEP population, the number of 

languages spoken, and the extent of public transit use.5

 We conducted 

semistructured interviews with officials from 20 transit agencies, 7 MPOs, 

and 16 community and advocacy groups and reviewed various documents 

and other information. We complemented these case studies and 

interviews with findings from a 2004 study, conducted for the New Jersey 

Department of Transportation, which included a survey of 32 transit 

agencies around the country, and surveys and focus groups with LEP 

persons in New Jersey.6

 To understand how DOT assists transit agencies 

and MPOs in providing language access services, we interviewed DOT 

officials with knowledge of the resources available on language access. We 

reviewed and analyzed the assistance provided by DOT as well as other 

federal resources related to language access. To document how DOT’s 

Federal Transit Administration (FTA) and Federal Highway Administration 

(FHWA) monitor transit agencies’ and MPOs’ provision of language access 

services, we interviewed FTA officials responsible for Title VI compliance 

reviews and triennial reviews, FTA and FHWA officials responsible for 

planning certification reviews, and regional officials in the areas we visited. 

We reviewed the documentation and results of these three review 

processes and analyzed the extent to which language access is considered 

by the reviews and norms have been developed for reviewers to use in 

identifying deficiencies related to language access. Furthermore, we 

reviewed the status and outcomes of LEP complaints that were made to 

FTA against transit agencies and MPOs. We conducted our work from 

February 2005 through October 2005 in accordance with generally 

accepted government auditing standards. Appendix I contains more 

information about our scope and methodology.

4

The metropolitan statistical areas we visited were as follows: (1) Los 

Angeles/Riverside/Orange County, California; (2) San Francisco/Oakland/San Jose, 

California; (3) Chicago/Gary/Kenosha, Illinois, Indiana, Wisconsin; (4) Austin/San Marcos, 

Texas; (5) Fayetteville/Springdale/Rogers, Arkansas; (6) Raleigh/Durham/Chapel Hill, North 

Carolina; and (7) Greensboro/Winston-Salem/High Point, North Carolina. 

5

We did not include in our site visits, areas that recently had in-depth reviews by FTA as well 

as agencies that had been highlighted in a recent report prepared for the New Jersey 

Department of Transportation, in order to broaden the limited amount of research and data 

available in this area.

6

Dr. Rongfang (Rachel) Liu, Mobility Information Needs of Limited English Proficiency 

(LEP) Travelers in New Jersey (December 2004). Dr. Liu prepared this study for the New 

Jersey Department of Transportation/Federal Highway Administration. The results of this 

study cannot be generalized to all transit agencies or to all LEP persons. 
Page 6 GAO-06-52 Language Access to Transportation Services

Results in Brief Transit agencies and MPOs provided a variety of types and levels of 

language access services, predominantly in Spanish, with the effects and 

costs of these services largely unknown, although the cost burden of these 

services currently does not seem significant. The types of language access 

that these agencies provided included a wide variety of communication 

strategies, such as translated information brochures and signs, multilingual 

telephone services, translated Web sites, bilingual drivers and customer 

service staff, translated recorded announcements, and interpreters at 

public and community meetings. Almost all of the 27 transit agencies and 

MPOs we visited provided some materials and services in at least one 

language other than English, typically Spanish, although few agencies we 

visited regularly provided much material or service in other languages. For 

example, although most of the transit agencies we visited had at least 

Spanish-speaking operators available through their telephone information 

lines, only 7 transit agencies utilized multilingual telephone lines to provide 

service in languages other than English and Spanish. The effects of the 

language access services provided by transit agencies and MPOs on 

meeting the needs of LEP communities are not well known or understood. 

Few agencies we visited had conducted an explicit assessment of the needs 

of the LEP communities in their service areas, or an evaluation of the 

effectiveness of their language access efforts, even though DOT’s LEP 

guidance recommends such activities. As a result, it is unclear whether 

those agencies’ language access activities are comprehensive enough to 

meet the needs of LEP persons, and community and advocacy groups in the 

areas we visited perceived important gaps in agencies’ language access 

activities. For example, 1 group told us that information on service changes 

is not consistently provided in languages other than English, which can 

result in LEP individuals waiting for buses that were rerouted. 

Furthermore, our case studies suggested that a lack of proactive agency 

outreach and publicizing of agency services to LEP communities may limit 

the impact and utilization of the materials and services provided, whereas 

more proactive agency outreach and publicizing to these communities 

might result in increased utilization of the services and benefits, such as 

enhanced public support for the agency and increased ridership. For 

example, although several transit agencies provided multilingual telephone 

services, community groups we spoke with often were not aware of the 

existence of such services. While costs related to providing language 

access services are largely unknown, we found that several agencies 

perceive providing language access as a cost of doing business, not as an 

additional cost, at the current level of activity. However, if the agencies 

were to significantly expand their efforts to include additional languages 
Page 7 GAO-06-52 Language Access to Transportation Services

beyond English and Spanish, additional materials, or additional services, 

agency officials told us that costs could become prohibitive. 

DOT and its modal administrations assist grantees in providing language 

access through DOT’s guidance and other activities, but they have made 

limited efforts to ensure that grantees are aware of this available 

assistance, which was not often accessed by the transit agencies and MPOs 

we visited. The most extensive assistance DOT provides is the LEP 

guidance itself, which provides grantees with a five-step framework for 

how to provide meaningful access to LEP populations, along with some 

information on how to implement such a framework. DOT’s LEP guidance 

was published in the Federal Register, but was not publicized through any 

other direct methods, and the majority of transit agencies and MPOs we 

visited were not aware of it. In part, this lack of awareness may be due to 

staff turnover within agencies since the initial release of the guidance, 

although a DOT official told us that they have done little to promote the 

guidance since its release. Of the 9 transit agencies and 3 MPOs we visited 

that were aware of the guidance, only 3 had changed their language access 

activities in response to it, and only 1 transit agency appeared to have fully 

implemented the five-step framework. In part, this is because most transit 

agencies and MPOs told us that they already had been providing language 

access services for many years prior to the executive order and DOT’s LEP 

guidance. In addition, FTA and FHWA have given workshops at a few 

annual conferences that specifically addressed the framework in the 

guidance and provided information on how to implement portions of it, but 

few agencies we visited had reported attending these workshops. DOT also 

participates in the Federal Interagency Working Group on Limited English 

Proficiency, which provides information and technical assistance to federal 

grantees through an on-line clearinghouse at http://www.lep.gov, although 

most of the Web site’s information is not specific to transportation. Other 

DOT resources, such as peer-exchange programs hosted by FTA and 

FHWA, have a few postings that discuss language access activities. Training 

curricula offered through FTA’s National Transit Institute and FHWA’s 

National Highway Institute touch on language access services through a 

broader context, such as the transportation planning process, and not all of 

these curricula specifically mention the guidance. Several transit agencies 

and MPOs we visited stated that better training and technical assistance 

that is easily accessible and specific to language access and on how to 

implement DOT’s LEP guidance could provide them with ways to more 

effectively provide access to LEP populations.
Page 8 GAO-06-52 Language Access to Transportation Services

Transit agencies’ and MPOs’ provision of language access services for LEP 

populations is monitored through FTA’s in-depth Title VI compliance 

reviews and two broader reviews—FTA’s triennial reviews of transit 

agencies and planning certification reviews conducted jointly by FTA and 

FHWA. However, these reviews do not assess grantees’ activities according 

to the framework in DOT’s guidance and do not have consistent criteria for 

determining whether an agency is deficient in providing such services. 

While the framework and suggestions contained in DOT’s LEP guidance are 

not requirements, they serve as a useful guide for ensuring that grantees’ 

provision of language access services to LEP persons is in compliance with 

federal requirements under Title VI. However, the Title VI compliance 

reviews and the planning certification reviews do not incorporate the LEP 

guidance, and the triennial reviews have only a few specific questions 

referencing the LEP guidance. Deficiencies regarding language access, to 

the extent they exist, are rarely identified during these review processes. 

Furthermore, the criteria that are used in these review processes to identify 

a deficiency in providing language access services are inconsistent and 

unclear. For example, under triennial reviews, a deficiency is only 

determined if a complaint has been made against the local agency, although 

under the other reviews, a complaint need not be made for a deficiency to 

be found. As a result, what constitutes a deficiency under one review may 

not constitute a deficiency under another, although agencies under review 

may be providing the same level of service. In addition to the three review 

processes, FTA investigates Title VI complaints filed by the public alleging 

national origin discrimination against LEP persons. FTA’s investigations 

focus on whether a recipient has taken reasonable steps to provide 

meaningful access to LEP persons. To date, FTA has received only one 

complaint related to language access. In that case, FTA found that the 

agency under question should have provided language access to its 

planning process. Without more thorough and consistent monitoring that 

takes into account DOT’s guidance, agencies’ language access activities are 

likely to remain varied and inconsistent and may leave agencies open to 

further complaints. 

We are making recommendations in this report that the Secretary of 

Transportation take actions to ensure that DOT grantees are made fully 

aware of the agency’s LEP guidance and their related responsibilities, that 

transit agencies and MPOs are provided with useful assistance in 

developing and improving their language access services, and that 

mechanisms are in place for clear and consistent oversight and monitoring 

of transit agencies’ and MPOs’ language access activities. In commenting 

on a draft of this report, DOT generally concurred with the findings and 
Page 9 GAO-06-52 Language Access to Transportation Services

recommendations and offered a number of technical comments, which 

were incorporated as appropriate. 

Background The statutory and regulatory framework for improving access to services 

for LEP persons stems from Title VI of the Civil Rights Act of 1964,7

 an 

executive order, DOJ regulations and guidance, and DOT regulations and

guidance. Section 601 of Title VI provides that no person shall “on the 

ground of race, color, or national origin, be excluded from participation in, 

be denied the benefits of, or be subjected to discrimination under any 

program or activity receiving Federal financial assistance.”8

 Section 602 of 

Title VI directs federal agencies to implement section 601 of the act by 

issuing rules, regulations, or orders.9

 In its efforts to implement section 601, 

DOJ has issued regulations that bar unjustified disparate impact on the 

basis of national origin.10

On August 11, 2000, President Clinton issued Executive Order 13166 to 

improve access to federally conducted and federally assisted programs and 

activities for persons who, as a result of national origin, are limited in their 

English proficiency.11 The order encouraged all federal agencies to take 

steps to ensure that any recipients of federal financial assistance under 

their purview provide meaningful access to their LEP applicants and 

beneficiaries. The order further requires that each federal agency providing 

federal financial assistance to prepare guidance specifically tailored to its 

recipients. The agencies’ guidance must then be reviewed and approved by 

DOJ before being issued. 

7

42 U.S.C. § 2000d et. seq. 

8

42 U.S.C. § 2000d. 

9

42 U.S.C. § 2000d-1.

10Disparate impact claims involve practices that are facially neutral in their treatment of 

different groups but that, in fact, fall more harshly on one group than another and cannot be 

justified by business necessity. Raytheon Co. v. Hernandez, 540 U.S. 44 (2003). Under the 

disparate impact theory of discrimination, a facially neutral practice may be deemed 

illegally discriminatory without evidence of subjective intent to discriminate, which is 

required in disparate-treatment cases.

1165 Fed. Reg. 50121. 
Page 10 GAO-06-52 Language Access to Transportation Services

DOJ released guidance12 in 2000 that set forth general principles for federal 

agencies to apply to ensure that their programs and activities provide 

reasonable access to LEP persons and, thus, do not discriminate on the 

basis of national origin. The DOJ guidance explains that, with respect to 

federally assisted programs and activities, Executive Order 13166 “does not 

create new obligations, but rather, clarifies existing Title VI 

responsibilities.” Although Title VI and its implementing regulations require 

that recipients take reasonable steps to ensure meaningful access by LEP 

persons, federal agencies’ LEP guidance recognize that each situation is 

fact-specific, and that it would not make sense for the guidance to mandate 

specific approaches to comply with Title VI. Rather, the purpose of federal 

agencies’ guidance is to provide recipients with a framework for assessing 

their obligations under Title VI, while maintaining flexibility for the 

recipients to determine how best to comply with those obligations. Thus, 

the guidance outlines steps federal-funds recipients can take to avoid 

administering programs in a way that results in discrimination on the basis 

of national origin, which would be in violation of Title VI regulations.13 In 

general, the test for assessing the existence of national origin 

discrimination on the basis of language under Title VI is to determine 

whether the failure to provide a service in a language that a recipient 

understands will prevent the recipient from receiving essentially the same 

level of service benefit as an English speaker.

1265 Fed. Reg. 50123. Additionally, DOJ developed its own guidance document for its funding 

recipients, which was initially issued on January 16, 2001. 66 Fed. Reg. 3834. Revised 

guidance was issued on June 18, 2002, after revising the guidance to reflect public 

comments. 67 Fed. Reg. 41455. 

13In Lau v. Nichols, 414 U.S. 563 (1974), the Supreme Court interpreted regulations similar 

to the DOJ regulations, and held that Title VI prohibits conduct that has a disproportionate 

effect on LEP persons because such conduct constitutes national-origin discrimination. The 

Court held that a San Francisco school district that had a significant number of non-Englishspeaking students of Chinese origin was required to take reasonable steps to provide them 

with a meaningful opportunity to participate in federally funded educational programs. In 

Alexander v. Sandoval, 532 U.S. 275 (2001), a non-English-speaking applicant for a driver’s 

license brought a lawsuit challenging Alabama’s requirement that driver’s license 

examinations be conducted only in the English language. The plaintiff claimed that this 

violated Title VI of the Civil Rights Act of 1964 by discriminating against non-English 

speakers on the basis of their national origin. Without addressing the merits of the claim, the 

Supreme Court held that a private individual was not entitled to file a lawsuit to enforce DOJ 

regulations on disparate impact under Title VI. DOJ has emphasized that the Court did not 

invalidate its regulations under Title VI or Executive Order 13166, and that those remain in 

force. See the October 26, 2001, Memorandum for Heads of Departments and Agencies 

General Counsels and Civil Rights Directors from Ralph F. Boyd, Jr., Assistant Attorney 

General, Civil Rights Division.
Page 11 GAO-06-52 Language Access to Transportation Services

DOJ’s guidance established a four-factor analysis to help determine the 

extent of a funding recipient’s obligation to provide LEP services. These 

four factors are (1) the number or proportion of LEP persons eligible to be 

served or likely to be encountered by the program or grantee; (2) the 

frequency with which LEP persons come in contact with the program; (3) 

the nature and importance to people’s lives of the program, activity, or 

service provided by the grantee; and (4) the resources available to the 

grantee and costs. According to DOJ, the intent of the analysis is to suggest 

a balance that ensures meaningful access by LEP persons to critical 

services, while not imposing undue burdens on small businesses, local 

governments, or nonprofits.

DOT issued its guidance in 2001. This guidance was generally consistent 

with DOJ’s guidance but included three additional factors, as well as the 

four factors previously outlined, suggesting that funding recipients should 

also consider (1) the level of services provided to fully English-proficient 

people; (2) whether LEP persons are being excluded from services, or are 

being provided a lower level of services; and (3) whether the agency has 

adequate justification for restrictions, if any, on special language services. 

The guidance states that such restrictions would be accepted only in rare 

circumstances. On the basis of public comments, DOT subsequently 

revised its guidance, and the revised guidance was approved by DOJ on 

August 25, 2005. DOT is currently preparing to publish and release its 

revised guidance. 

In addition to describing factors that funding recipients should consider in 

assessing their obligations to provide LEP services, DOT’s guidance 

outlines several key components to an effective language access program, 

stating that grantees should (1) conduct an assessment of the language 

groups within their service areas and the language needs of these groups; 

(2) develop and implement written plans outlining their strategies for 

ensuring access to services for LEP populations; (3) make staffs aware of 

the LEP access plan, and train the staffs and provide them with the tools 

necessary to carry out the plan; (4) ensure that language access services 

are actually provided in a consistent manner, and that LEP populations are 

aware of the services; and (5) develop monitoring programs that allow 

grantees to assess the success of their LEP access programs and to identify 

needed modifications. These five steps are designed to help DOT grantees 

ensure that they are not administering their programs in a way that results 

in discrimination in violation of Title VI.
Page 12 GAO-06-52 Language Access to Transportation Services

Several offices within DOT, particularly the Office of Civil Rights within 

FTA, have responsibility for ensuring that transit operators and 

transportation planning entities receiving DOT funds are in compliance 

with Title VI and responsibility for monitoring and overseeing their

language access activities.

Several Types of 

Language Access 

Services Are Provided, 

but Little Is Known 

about the Effects and 

Costs of Services 

The types of language access services provided by the transit agencies and 

MPOs we visited included translated service brochures, multilingual 

telephone lines, translated Web sites, bilingual customer service staffs, and 

a host of other services. However, the effects and costs of these services 

are largely unknown. The extent of language access provided varied across 

the areas we visited during our case studies, and services provided often 

varied across agencies within the same metropolitan area. Almost all of the 

transit agencies and MPOs we visited provided at least some language 

access services in Spanish, the largest LEP language group, and some 

agencies provided services in other languages. Little is known about the 

effects of these services on improving access to public transportation and 

the transportation planning and decision-making process for LEP 

populations, but community and advocacy groups in the areas we visited 

identified several gaps in the language access services provided by 

agencies, such as a lack of awareness in the community about the services 

available. Given such problems, community groups told us that more 

proactive agency outreach to LEP communities to determine specific needs 

and advertise existing services might improve the effectiveness of language 

access services, whereas a lack of outreach and poor publicizing of 

available services could likely reduce the impact and utilization of the 

materials and services provided. One agency cited the positive benefits it 

received by improving its outreach to non-English-speaking populations, 

including increased ridership and enhanced public support for the agency. 

Little is also known about the costs of providing such services, and most 

agencies saw the language access they provide as a cost of doing business 

as opposed to an additional cost; however, agencies told us that costs could 

become prohibitive if services were substantially expanded or provided in 

several additional languages. 
Page 13 GAO-06-52 Language Access to Transportation Services

Types and Level of 

Language Access Services 

Varied, Although Core 

Services Are Offered in 

Spanish by Most Agencies 

We Visited

During our case studies, we found that providing language access to LEP 

populations can be incorporated into all of the different ways in which 

transit agencies and MPOs communicate with the public, not only 

regarding the transportation services they provide but regarding how 

agencies provide LEP communities with access to the transportation 

planning and decision-making process. Transit riders and potential transit 

riders may need a variety of different types of information to plan their 

trips, use the transit system, and participate in the transportation planning 

and decision-making process. For example, potential riders may need to 

know about the existence of available services, destinations, and travel 

options, and about time schedules, route options, and transfer policies. 

When in the transit system, riders may need to know where stops are 

located, whether service changes have occurred, about available fare and 

payment options, and about emergency and safety information. Riders may 

also need confirmation that they are on the right route or are exiting at the 

correct stop. To participate in the transportation planning and decisionmaking process, individuals need to know how the process works, what is 

the purpose and effect of their participation, and when and where public 

meetings are being held, in addition to needing to be able to understand the 

proceedings of public meetings and to make statements and participate in 

those discussions. 

To provide such access to LEP populations, transit agencies and MPOs 

employed a host of different communication strategies, including the 

following: providing bilingual or multilingual telephone services; 

translating written materials; translating signs or notices posted at stations, 

at stops, or on vehicles; providing in-person language assistance through 

drivers, interpreters, or multilingual customer service staffs; advertising in 

other languages on television, on radio, or in newspapers; translating 

materials on their Web sites; translating recorded announcements or 

electronic signs; or making ticket machines accessible in other languages. 

In providing language access, the agencies in each of the areas we visited 

faced different challenges. In North Carolina and northwest Arkansas, 

agencies are facing a substantial recent growth in the size of the Spanishspeaking population. (See app. I for more information on the size and 

growth of LEP populations in these two areas.) In parts of California—the 

San Francisco Bay Area and the Los Angeles and Orange County areas—

and in Chicago, Illinois, the predominance of a number of Asian and other 

language groups, in addition to a large percentage of Spanish-speakers, 

presents further challenges. Agencies in Austin, Texas, have also 

experienced growth in Asian languages spoken in the area. Figure 3 shows 

the percentages of the transit agencies and MPOs we visited that provided 
Page 14 GAO-06-52 Language Access to Transportation Services

services in at least Spanish for each of these communication strategies. 

However, in some cases, agencies may not utilize these communication 

strategies, even in English, and these agencies are not included in the 

percentage calculation. 

Figure 3: Percentage of Transit Agencies and MPOs We Visited That Make These 

Types of Language Access Services Available in at Least Spanish

Note: Some agencies provide information and services in other languages, in addition to English and 

Spanish. We visited 20 transit agencies during our site visits. 

a

Included in this percentage are 20 transit agencies and 7 MPOs.

b

Included in this percentage are 20 transit agencies and 7 MPOs. Four transit agencies and 1 MPO 

posted translated information to their Web sites without indication that the translated material was 

available.

c

Included in this percentage are just the 12 transit agencies that have recorded announcements or 

electronic signs.

d

Included in this percentage are just the 5 transit agencies that utilize electronic ticket machines. 

The following sections discuss transit agency and MPO activities within 

each of the broad categories shown in figure 3, and highlight examples 

from the seven metropolitan statistical areas we visited. Following the 

discussion of these activities, we further discuss agencies’ community 

Language Access Services

Percentage

Source: GAO analysis of site visit data.

0 20 40 60 80 100

Bilingual or multilingual

electronic ticket machinesd

Translated recorded announcements

and electronic signsc

Bilingual or multilingual translated 

materials on Web sitesb

Bilingual or multilingual television, 

radio, and newspaper advertisementsa

In-person language assistancea

Translated signs and notices

Translated printed

service informationa

Bilingual or multilingual

telephone services

20

33

52

78

78

80

82

95
Page 15 GAO-06-52 Language Access to Transportation Services

outreach activities related to LEP populations and to the community and 

advocacy groups that represent them.

Bilingual or Multilingual 

Telephone Services

All but 1 of the 20 transit agencies we visited had at least some telephone 

operators who were bilingual in English and Spanish, but the availability of 

telephone information in other languages varied. In contrast, a survey of 32 

transit agencies conducted for the New Jersey Department of 

Transportation found that only one-half of responding agencies used 

multilingual telephone lines or bilingual or multilingual persons in call 

centers.14 A few transit agencies we visited in highly diverse areas, such as 

San Francisco and Los Angeles, had operators fluent in other languages. 

For example: 

• The Metropolitan Transportation Authority in Los Angeles and San 

Francisco’s Municipal Transportation Agency have operators that speak 

Tagalog and Chinese.

• The Bay Area Rapid Transit has Chinese-speakers available in its call 

center.

In other cases, telephone services were not language accessible. For 

example, the San Francisco Bay Area’s 511 traveler information line, which 

provides information on all of the transportation options available in the 

area, is currently only accessible in English. 

Transit agencies in Chicago; Los Angeles; Orange County; and Greensboro, 

North Carolina, had access to a three-way call translation service in 

numerous languages. While this service is available through these agencies’ 

general transit information lines, which are advertised on most agency 

materials, the fact that translation services are available through the threeway call service is not well publicized. Therefore, LEP persons may not be 

aware of these translation services. For example, representatives of a 

Chinese community center in Chicago were not aware that Chinese 

translators were available through the Chicago Regional Transportation 

Authority’s language line, although those representatives said they often 

assist new Chinese immigrants in learning how to use the transit system. In 

addition, the New Jersey study found, through its surveys and focus groups 

with LEP persons, that awareness of the existence of the translation 

services available in New Jersey was very low, although the study found 

14Liu, Mobility Information Needs of LEP Travelers, p. 32.
Page 16 GAO-06-52 Language Access to Transportation Services

such services to be valued by LEP persons.15 Some community groups also 

pointed to the availability of bilingual or multilingual operators as one of 

the most critical and useful services that agencies can provide to LEP 

persons. Without such services, LEP persons must rely on family, friends, 

or other transit riders who speak their language to provide assistance. 

Transit agencies told us that complaints in other languages could also be 

taken through their bilingual or multilingual telephone services; many 

agencies had received complaints in languages other than English, 

primarily in Spanish. However, specific complaints about language access 

were rare, with only 1 agency reporting such a complaint in relation to a 

rider’s having trouble communicating with a driver. 

In some areas we visited, other nontransportation agencies receiving 

federal financial assistance also had contracts for multilingual telephone 

translation services. Because those agencies also are subject to the 

executive order and federal agency LEP guidance, the existence of such 

contracts presents an opportunity for local agencies to coordinate in order 

to more efficiently provide such services. Few of the transit agencies or 

MPOs we visited had coordinated with any other nontransportation 

agencies in their service areas in this regard. However, in North Carolina, 

transit agencies in Raleigh, Durham, Chapel Hill, and Greensboro all have 

relationships with other city departments that can assist with language 

access needs, such as sharing bilingual operators.

Translated Printed Service 

Information

All but 2 of the 20 transit agencies we visited printed at least some 

schedules and maps, how-to-ride guides, applications for specialized 

transportation, or other service information materials in Spanish, and many 

transit agencies provided extensive amounts of printed materials in 

Spanish. (See fig. 4 for a sample of a translated service information 

brochure.) In addition, the New Jersey survey of 32 transit agencies found 

that two-thirds of responding agencies provided translated timetables and 

route maps.16 However, officials at 3 transit agencies indicated that they 

often do not translate the language on maps and schedules because most of 

the information consists of numbers, which are universal. 

15Liu, Mobility Information Needs of LEP Travelers, p. 29.

16Liu, Mobility Information Needs of LEP Travelers, p. 32.
Page 17 GAO-06-52 Language Access to Transportation Services

Figure 4: English and Spanish Versions of the Los Angeles County Metropolitan 

Transportation Authority’s Rider’s Guide

Seven transit agencies we visited also provided selected guides and maps in 

languages other than Spanish that are prevalent in their service areas, and 4 

agencies are able to provide translated materials upon request. Some 

examples include the following:

Source: Los Angeles County Metropolitan Transportation Authority.
Page 18 GAO-06-52 Language Access to Transportation Services

• The Alameda-Contra Costa Transit District in the San Francisco Bay 

Area regularly prints service information in Spanish and Chinese.

• Also in the San Francisco Bay Area, the Bay Area Rapid Transit’s rider’s 

guide is printed in Spanish and Chinese. 

• On request, the Los Angeles County Metropolitan Transportation 

Authority can provide information in several other languages, although 

the agency acknowledged that such requests were very rare. The agency 

also produced informational brochures in Chinese to advertise the 

opening of its Gold Line light-rail service, which passes through 

Chinatown in downtown Los Angeles. 

Some community groups we spoke with indicated that, if service 

information materials are not translated, many LEP transit riders will likely 

learn to use the system from family, friends, or others in their community. 

However, a lack of translated printed materials may discourage use of the 

system or participation in the transportation planning and decision-making 

process by affected language groups. Officials at 1 agency told us that 

providing information in the language the community is most comfortable 

with sends a message that they are welcome on the system and in the 

planning process, while not doing so may send the message that they are 

unwelcome. Community groups also told us that more translated service 

information could encourage greater ridership and make the system more 

welcoming to LEP persons. In addition, the New Jersey study found that, 

next to having a staff person speaking their native language, LEP groups 

most preferred to have timetable, schedule, and other information in their 

native language.17

While MPOs can serve a variety of functions and may provide a wide 

variety of services related to transportation, we specifically focused on 

informational materials related to transportation planning and public 

involvement provided by MPOs we visited. Three of the 7 MPOs we visited 

had translated a summary of their transportation plan into Spanish, with 1 

MPO, the Metropolitan Transportation Commission in the San Francisco 

Bay Area, also translating the document into Chinese. Two MPOs had 

translated a citizen’s guide to participation in the transportation planning 

process into Spanish. Another MPO had translated a transportation needs 

survey into Spanish. 

17Liu, Mobility Information Needs of LEP Travelers, p. 28.
Page 19 GAO-06-52 Language Access to Transportation Services

Bilingual or Multilingual Signs 

and Service Change Notices

Transit agencies we visited provided several different types of translated 

signs in vehicles or at stations and stops. Of the 4 agencies out of 20 that 

did not have such signs, 2 were primarily paratransit operators whose 

vehicles are operated by contractors. The types of translated signs 

provided included basic service information on bus stop signs, postings of 

service changes, fare box signs, emergency exit and priority-seating signs, 

public meeting notices, and posters for informational campaigns. Without 

translated postings of service changes, bus stop closures, or fare policies, 

LEP persons are at a disadvantage in accessing the transit system. One 

community group cited an instance of LEP persons waiting at a bus stop 

that had been closed due to a city event. This situation occurred because 

the transit agency had not posted translated notices at the bus stop 

announcing the closures. 

Of the transit agencies we visited, 8 had some basic service information 

signs at rail stations or bus stops available in languages other than English, 

and 1 agency we visited had such information available in languages other 

than Spanish at selected bus stops. For example, Transportation 

Authorities in Orange County and Los Angeles provide some information at 

some bus stops in Spanish (such as the direction of travel and information 

on their telephone lines). One agency, the Alameda-Contra Costa Transit 

District in Oakland, estimates that approximately 750 of its 1,200 signs are 

translated in Chinese and Spanish, with signs in bus shelters in the city of 

Oakland, California, now being replaced with seven-language signs, an 

example of which is shown in figure 5.
Page 20 GAO-06-52 Language Access to Transportation Services

Figure 5: Seven-Language Bus Stop Sign in Oakland, California

Source: Alameda-Contra Costa Transit District.
Page 21 GAO-06-52 Language Access to Transportation Services

Officials at 3 transit agencies stated that they had not translated street 

signs, or did not translate the entire sign, because much of the information 

is numeric and because including several languages on such signs would 

become unwieldy for transit riders to effectively use. Agency officials also 

indicated that cost could become an issue in replacing all of the signs 

throughout their systems, and some agencies were looking into utilizing 

more pictograms in order to avoid the use of multiple languages while 

providing more universal access. However, some community group 

representatives told us that, although the use of pictograms can be a useful 

way to communicate with non-English speakers, some translated language 

may need to accompany the pictograms in order for the information to be 

communicated effectively. 

Several of the transit agencies we visited posted or provided, in languages 

other than English, information on service changes or closures at rail 

stations, at bus stops, and in vehicles. Some examples include the 

following:

• The Orange County Transportation Authority puts service change flyers 

in English and Spanish in vehicles on affected bus routes. 

• The Golden Gate Transit in San Francisco posts Spanish and English 

service change notices at its central transit hub. 

• The Alameda-Contra Costa Transit District provides service change 

brochures in Chinese and Spanish. 

Ten transit agencies had on-board signs that included information on fares 

or emergency exits and priority-seating signs for elderly and disabled 

persons, and 10 agencies posted public meeting notices on their vehicles, 

translated into at least Spanish. A few agencies also provided fare 

information or posted public meeting notices on buses or in stations in 

other languages. For example:

• The San Francisco Municipal Transportation Agency and the AlamedaContra Costa Transit District both provide fare information in Chinese 

and Spanish.

• The San Francisco Municipal Transportation Agency posts some 

meeting notices on its vehicles in Chinese and English, as shown in 

figure 6. 
Page 22 GAO-06-52 Language Access to Transportation Services

Figure 6: Meeting Notice Posted on a Bus in San Francisco, California, in English 

and Chinese

In addition, some transit agencies we visited had translated other types of 

signs, such as posters in English and Spanish, generally designed under the 

auspices of new initiatives or information campaigns. For example, 

METRA Commuter Rail in Chicago and the Los Angeles County 

Metropolitan Transportation Authority both placed posters in English and 

Spanish that highlight safety issues on those systems. Orange County 

Transportation Authority officials credit the wide acceptance of the 

agency’s new “no pennies” fare policy to the bilingual “Hasta Luego 

Pennies” campaign, as shown in figure 7.

Source: The San Francisco Municipal Transportation Agency.
Page 23 GAO-06-52 Language Access to Transportation Services

Figure 7: Posters in Orange County, California, in English and Spanish

In-Person Language Assistance While all but 3 of the transit agencies we visited had bilingual drivers on 

staff, some agency officials noted that those drivers are generally not 

required or instructed to make announcements in other languages and are 

generally not assigned to routes where their language skills may be useful. 

Some agency officials indicated that union rules allow drivers to select 

preferred routes on the basis of seniority. Therefore, there is no indication 

of the number of bilingual drivers that are utilizing their languages skills, 

although agency officials knew of individual occurrences. Three agencies 

we visited—Golden Gate Transit in California; Capital Metro in Austin, 

Texas; and Chapel Hill Transit in North Carolina—had provided their 

drivers with useful phrase or word guides in Spanish, an example of which 
Page 24 GAO-06-52 Language Access to Transportation Services

is shown in figure 8. A few other agencies, including the Capital Area Rural 

Transportation System and the Capital Metro in Austin, Texas, and the 

Ozark Regional Transit in northwest Arkansas, have bilingual employees 

available to translate over the radio on the bus.
Page 25 GAO-06-52 Language Access to Transportation Services

Figure 8: Golden Gate Transit’s Spanish Phrase Guide for Drivers

Source: Golden Gate Transit.
Page 26 GAO-06-52 Language Access to Transportation Services

Many of the transit agencies reported that they had some bilingual staffs in 

customer information booths or ticket offices, although agencies tended 

not to look for bilingual customer service staffs in particular. Agency 

officials in several areas stated that customer service personnel have 

language skills because their employees reflect the ethnic and language 

diversity of their region. For public meetings related to the transportation 

planning and decision-making process, 12 transit agencies and 4 MPOs had 

Spanish interpreters or bilingual employees or board members available if 

needed at most public meetings, while 6 transit agencies and 3 MPOs had 

Spanish interpreters available by request. In areas where there is a 

preponderance of other languages spoken, interpreters in languages other 

than Spanish were generally provided on a “by-request” basis, although 1 

agency reported that it regularly provided Chinese translators. 

While 16 transit agencies we visited had cultural sensitivity included in 

their staff training, only 9 provided training or technical assistance to their 

employees that directly related to LEP issues. The New Jersey survey of 

transit agencies found that only one-quarter of the responding agencies had 

training for customer service employees that was specific to LEP service.18

Five agencies we visited offered free Spanish classes to employees. For 

instance, Chapel Hill Transit hired a contractor to teach conversational 

Spanish to supervisors, dispatchers, and those employees who answer 

telephones during work hours. The agency has not been able to offer the 

course to drivers because of budgeting issues, since attending the course 

would be considered part of the drivers’ work week and they would have to 

be paid overtime. However, the town of Chapel Hill does offer tuition 

reimbursement to drivers who want to take Spanish classes on their own 

time. 

Community groups regularly pointed out the importance of having as many 

bilingual bus drivers and customer service staff as possible. At a 

community meeting in Aurora, Illinois, held by the Chicago Area 

Transportation Study, the need for more bilingual bus drivers was 

highlighted as a community transportation need. The New Jersey focus 

groups with LEP travelers also found that the inability to communicate 

with bus drivers was one of the chief complaints of the LEP travelers in 

New Jersey.19 In terms of the availability of interpreters at public meetings, 

18Liu, Mobility Information Needs of LEP Travelers, p. 32.

19Liu, Mobility Information Needs of LEP Travelers, pp. 27-28. 
Page 27 GAO-06-52 Language Access to Transportation Services

community groups we met with criticized the fact that interpreters are 

frequently only provided on a “by-request” basis. Agencies generally require 

that requests be made 3 days in advance of the meeting, but community 

groups told us that if an agency is advertising the meeting in different 

languages, as many of the agencies we visited did, they should be prepared 

to provide access to the proceedings of the meeting in those languages, 

rather than relying on the public to request translation.

Bilingual or Multilingual 

Television, Radio, and 

Newspaper Advertisements

Fourteen transit agencies and 6 MPOs we visited posted notices of public 

meetings in newspapers printed in languages other than English—with 10 

posting notices in more than one language. A few agencies posted such 

notices in as many as five different language newspapers. For example, the 

Los Angeles County Metropolitan Transportation Authority publishes its 

“Metro Briefs,” which includes notices of public meetings and other 

information, in Thai, Korean, Chinese, Armenian, and Spanish language 

newspapers. Spanish radio and television advertisements were also placed 

by several agencies, sometimes in relation to ongoing information 

campaigns, such as rail safety campaigns. For example, METRA Commuter 

Rail in Chicago advertised its rail safety campaign on television and radio in 

Spanish.

Bilingual or Multilingual 

Translated Materials on Web 

sites

Eleven of the 20 transit agencies we visited had some information on their 

Web sites that was available in other languages; however, 4 of the 11 made 

no indication on their home pages that translated materials were available. 

Of the 7 MPOs we visited, 3 had such translated information posted on their 

Web sites, and 2 had links on their home pages indicating that translated 

materials were available. Some examples of translated Web sites include 

the following:

• The Alameda-Contra Costa Transit District’s Web site provides basic 

rider information in Spanish, Vietnamese, and Chinese—the three 

largest LEP populations in its service area—that is directly accessible 

through links in those languages on the home page. 

• The Regional Transportation Authority in Chicago, and the Bay Area 

Rapid Transit and the Golden Gate Transit in San Francisco, have basic 

transit information available in seven and eight other languages, 

respectively, indicated by country flag icons on the agencies’ home 

pages. The languages chosen are not fully reflective of the major LEP 

groups in these areas, however, because these Web sites also serve 

tourism purposes. For example, in Chicago, the Regional Transportation 

Authority’s Web site is translated into French, German, and Japanese, 
Page 28 GAO-06-52 Language Access to Transportation Services

although these are not major LEP groups in the city. However, the site is 

not accessible in Chinese, although Chinese is the third largest LEP 

population in Chicago.

Four transit agencies and 1 MPO had posted translated materials to their 

Web sites but did not indicate on the home pages that those materials were 

available. For example, materials translated into Spanish are posted on the 

Los Angeles County Metropolitan Transportation Authority’s Web site, but 

a user must navigate through links that are in English to get to them. Also, 

the San Francisco Municipal Transportation Agency has part of its Title VI 

plan translated into Spanish and Chinese, but the user must navigate 

through at least two links in English to find the translations. Only 1 agency 

we visited, the Ozark Regional Transit, a small urban operator in northwest 

Arkansas managed by First Transit, had made its entire Web site accessible 

in another language, Spanish, as seen in figure 9. A link in Spanish on the 

home page leads to a fully translated version of the Web site. Furthermore, 

while many agencies have Web-based trip planners, none of the agencies 

we visited had made that function fully available in other languages.20

20Two examples of agencies with language-accessible trip planners are the Washington 

Metropolitan Area Transportation Authority, which makes that function available in several 

languages, and the Tri-Met in Portland, which makes that function available in Spanish. We 

did not visit these agencies.
Page 29 GAO-06-52 Language Access to Transportation Services

Figure 9: Spanish Version of the Ozark Regional Transit’s Web Site Home Page

Translated Web sites were not frequently identified by community groups 

as being particularly useful for LEP persons because LEP persons often do 

not have access to the Internet, according to the community group 

representatives we met with. In addition, the New Jersey study found that 

LEP focus groups did not often rate translated Web sites as a major 

resource in addressing mobility needs.21 However, providing translated 

information on an agency Web site without indication in that language that 

it is available is likely to reduce the usefulness of that information to those 

LEP persons who do have Internet access.

21Liu, Mobility Information Needs of LEP Travelers, p. 29.

Source: Ozark Regional Transit, a public transit system managed by First Transit.
Page 30 GAO-06-52 Language Access to Transportation Services

Translated Recorded 

Announcements and Electronic 

Signs

Only 3 of the transit agencies we visited had recorded announcements in 

other languages on their vehicles or at their facilities, although many 

agencies do not utilize recorded announcements at all. Also, although a few 

transit agencies employ electronic media, such as televisions or ticker-tape 

style displays, only 1 provided translated information on its ticker-tape 

display. Examples of translated recorded announcements include the 

following:

• The Capital Metro in Austin provides recorded announcements on its 

buses in English and Spanish, which are also broadcast outside the bus 

at bus stops.

• The Bay Area Rapid Transit has Spanish and Chinese announcements 

recorded and available for use in the event of an emergency in its train 

stations or on its trains.

• The Gold Line light-rail line in Los Angeles has recorded announcements 

of stops and rider instructions in English and Spanish. 

Bilingual or Multilingual 

Electronic Ticket Machines

Of the transit agencies that utilize electronic ticket machines for rail 

services—the Chicago Transit Authority, the METRA Commuter Rail in 

Chicago, the Los Angeles County Metropolitan Transportation Authority, 

the Bay Area Rapid Transit, and the San Francisco Municipal 

Transportation Agency—only the Los Angeles County Metropolitan 

Transportation Authority had some machines accessible in English and 

Spanish. This agency has installed ticket machines that are accessible in 

Spanish on a newer light-rail line that passes through a predominantly 

Hispanic neighborhood, and officials told us they were considering 

replacing all ticket machines with machines that will be accessible in six to 

eight languages. One group we met with pointed out that, without 

translated information on fare discounts and without ticket machines that 

are language accessible, LEP persons may not be aware of the fare options 

available to them in the same manner that English speakers would be, 

potentially leading to LEP persons’ paying more than needed for their trips.

Communicating Directly with 

LEP Communities or Community 

and Advocacy Groups 

Representing LEP Persons 

Almost all of the transit agencies and MPOs we visited had made at least 

some effort to communicate more directly with communities and to 

conduct outreach with LEP communities and the community and advocacy 

groups that serve LEP persons. For example, in Greensboro, the city 

recently started a new program with Lutheran Family Services, a 

community group that works with many LEP persons, to provide an 

orientation for recent immigrants and refugees to the area. Under the 
Page 31 GAO-06-52 Language Access to Transportation Services

program, city departments identified as having the most public interaction 

with LEP persons, make an interactive presentation of services provided. 

These presentations are given in English and simultaneously translated into 

several languages, including Spanish, Vietnamese, Arabic, and Russian, 

depending on the availability of translators. The city is also producing a 

video on its services, including public transit, which will be translated into 

Spanish and into other languages upon request. In Orange County, the 

Orange County Transportation Authority conducts a program that includes 

visiting Spanish-speaking senior centers to inform seniors about the agency 

and its services. As part of the program, the agency will bring a bus to the 

centers and walk the seniors through every step of riding the bus, including 

getting on, paying the fare, and exiting. In addition, 2 agencies reported 

holding information sessions at bus terminals when service changes or fare 

adjustments are about to occur. For example, the Durham Area Transit 

Authority publicizes such information sessions in the Spanish community, 

and then has translators on hand at bus terminals to explain service 

changes and answer any questions. 

In terms of transportation planning and decision making, federal law and 

regulations require transit agencies and MPOs to involve the public in 

transportation planning and decision-making processes,22 and Title VI, as 

well as DOT’s guidance, suggests that agencies should also make this 

process accessible to non-English speakers. Providing language access to 

planning and decision making can include all of the communication 

strategies used by transit agencies and MPOs in this process. Some 

communication strategies for public participation will fall into the 

strategies previously outlined, such as providing interpreters at public 

meetings and posting translated notices of community or public meetings 

on Web sites, at stations, in vehicles, in newspapers, or on television or 

radio. Some agencies also employed more direct tactics to include LEP 

groups in the planning process. For example, several transit agencies and 

MPOs we visited mailed out notices of community and public meetings to 

community and advocacy groups representing LEP persons, although in 

some cases, these notices were not sent out in languages other than 

English. In addition, several agencies we visited distributed translated 

public meeting notices in various establishments throughout the 

community. For example, the Golden Gate Transit in the Bay Area 

distributes meeting notices in Spanish at convenience stores, restaurants, 

and laundromats in predominantly Hispanic neighborhoods. Some transit 

22For example, see 23 U.S.C. § 134 (i)(5) and 23 C.F.R. § 450.316(b). 
Page 32 GAO-06-52 Language Access to Transportation Services

agencies and MPOs also kept in regular contact with community and 

advocacy groups representing LEP persons or created specific advisory 

boards that occasionally influenced language access activities. For 

example, the Orange County Transportation Authority created a citizen’s 

advisory committee that pushed for the agency to provide translated 

notices of service changes. In addition, some agencies reached out directly 

to LEP communities with regard to the planning and decision-making 

process. For example, Capital Metro in Austin started an outreach 

campaign that involved sending teams of staff and volunteers, many of 

whom were bilingual, into the community to provide information on new 

transportation projects face-to-face. Capital Metro found that this outreach 

resulted in greater public support for the agency and in increased ridership. 

Despite some of these efforts, community group representatives we spoke 

with were often critical that agencies’ outreach efforts related to planning 

and decision making were generally not proactive and inclusive of LEP 

persons. For example, one representative we spoke with told us that 

attendance at a public meeting on transportation projects in a 

predominantly Chinese-speaking neighborhood was not well attended by 

members of that community, and that no Chinese translator was on hand at 

the meeting. This representative believed that better outreach to that 

community to encourage community involvement would have led to higher 

attendance. A representative of another group explained that community 

meetings are often very difficult to access for Spanish-speaking members 

of the community, and that the local MPO tends to work with elected 

officials rather than working more directly with members of the 

community.

In the New Jersey surveys and focus groups of LEP travelers, some LEP 

groups in New Jersey indicated that a lack of adequate transportation 

services was the biggest impediment to their mobility.23 Without access to 

and involvement with local transit agencies and planning entities, the needs 

of this community are not likely to be heard by these agencies. 

Furthermore, failing to provide language access to decision making can 

lead to complaints of discrimination. FTA has received one complaint that 

LEP persons were not given adequate access to the planning and decisionmaking process.

23Liu, Mobility Information Needs of LEP Travelers, p. 28.
Page 33 GAO-06-52 Language Access to Transportation Services

Effects of Language Access 

Services on Meeting Needs 

Are Not Well Known

The efficacy of the LEP access services provided is largely unknown due to 

a lack of data. Most transit agencies and MPOs we visited could provide 

only limited information about the utilization or effectiveness of their 

language access services. Furthermore, few of the agencies we visited had 

conducted a formalized assessment of the needs of the LEP populations in 

their service areas, or had assessed the success of their language access 

activities in meeting these needs, although DOT’s LEP guidance 

recommends that they do so. Data limitations were present in analyzing the 

effects of all types of LEP access services. For example, although some 

transit agencies print thousands of translated brochures, they do not keep 

track of how many brochures are placed on buses or in stations. In 

addition, because many brochures are printed with English and another 

language in the same booklet, it is impossible to know whether the 

language accessible section is being utilized. Data on the utilization of 

bilingual or multilingual telephone operators were also generally not 

available for the majority of the transit agencies because they do not 

formally track calls received in languages other than English. In those 

instances where calls were tracked, they were predominantly in Spanish, 

and calls in other languages were generally not common. For 1 transit 

agency, of the 378 calls in languages other than English that were received 

in 2004, 90 percent of them were in Spanish. For another, just 3 percent of 

calls were in languages other than English and Spanish. One agency in Los 

Angeles did receive a relatively large percentage of calls in Russian, Farsi, 

and Armenian to its language line. For Web sites, data on the utilization of 

multilingual pages were only available in some instances. Even when 

tracked, these Web site data were often inconclusive regarding how often 

the translations were accessed relative to English portions of the sites. 

Finally, information on the effectiveness of translated signs was not 

determined by any of the transit agencies or MPOs we visited. 

Although little effort had been made by the transit agencies and MPOs we 

visited to closely examine the impact of their LEP activities, a few agencies 

were considering language issues as part of their more comprehensive 

assessments of ongoing communication and outreach efforts. For example, 

the Regional Transportation Authority in Chicago has started a long-term 

study of the overall communication strategies of all the transit agencies in 

Chicago, including language access issues. Part of the study’s methodology 

was for a researcher to ride along with a LEP rider to identify areas where 

communication was lacking and the rider encountered problems. The 

study found that language barriers made it difficult to understand changes 

to schedules or service, or changes in how to navigate through the system. 
Page 34 GAO-06-52 Language Access to Transportation Services

The study is looking at an increased use of pictograms as one potential 

solution to making access easier for LEP populations. 

Despite the lack of supporting data, most agencies felt that they were 

adequately responding to the demand for language access services in their 

areas. Agency officials believed that because no complaints had been 

recorded concerning the level of language access provided, and because 

they generally did not receive many requests for translated materials or 

interpreters, they were doing a reasonable job of providing such access. 

Several agency officials did state that there was still room for 

improvement, and some were considering providing more information in 

languages other than Spanish. Agency officials also recognized the need for 

greater outreach efforts in general, especially for ethnic communities that 

may have language barriers, since turnout at public meetings by these 

groups is typically low. However, some agency officials told us that 

agencies may lack the needed staff to regularly conduct proactive 

community outreach activities. 

By contrast, community and advocacy groups we met with generally saw 

several shortcomings in the provision of language access services, 

sometimes within the larger context of how transit agencies and MPOs

communicate with the public in general. In their opinion, a lack of 

complaints regarding LEP issues did not necessarily mean that transit 

agencies were doing a satisfactory job, but rather might reflect the fact that 

many LEP persons were not likely to complain about the provision of 

language access services, due to cultural differences and wariness about 

interacting with government agencies. Many community group 

representatives we spoke with complained of a lack of knowledge in the 

community about the materials and services that were available, and a lack 

of materials in languages other than Spanish. Even in areas where transit 

agencies do provide translated materials, representatives of community 

groups stated that these materials were often not readily available or easy 

to locate. In addition, many community groups were unaware of the 

existence of multilingual telephone lines, or they complained that Spanishspeaking operators were often not available when they called. 

In addition to questioning the level of service information available to LEP 

populations, community groups cited concerns about the lack of actual 

transit services available to certain communities where large LEP 

populations reside, as well as concerns about a lack of effective 

involvement of these communities in the planning and decision-making 

process, as previously discussed in this report. Many representatives we 
Page 35 GAO-06-52 Language Access to Transportation Services

spoke with were unaware of public meetings held by transit agencies and 

MPOs, and they complained about the lack of ongoing communication with 

them and the communities they represent. Furthermore, representatives of 

community groups told us that these agencies rarely used them as a 

resource or consulted with them on LEP transportation issues. 

These representatives made several suggestions regarding how language 

access services could be improved, and which types of activities would 

likely be most effective in meeting community needs. Several suggestions 

involved facilitating the inclusion of ethnic communities, including LEP 

persons, in the planning process. For example, representatives from one 

group stated that public meetings should have agendas that are clear, 

specific, and of value to the community, and that these communities should 

be sought out and included early in the process. Other representatives 

stated that established community and advocacy groups should be used 

more effectively as a conduit to the community. Regarding language access 

services, community group representatives recommended having ticket 

machines and discount fare information available in other languages so 

that LEP communities could take advantage of fare discounts. They also 

said that having spoken announcements in other languages or having bus 

drivers or other personnel available to communicate in other languages 

would be highly effective in improving access for LEP persons. 

The New Jersey survey and focus groups of LEP travelers provided some 

data on the needs of LEP transit users. Like the community group 

representatives, some LEP groups in this study reported that inadequate 

service in their neighborhoods was their chief concern. In terms of travel 

assistance needed, LEP groups most often cited having a driver or staff 

person available to assist them in their own language. Reaction was split 

among LEP travelers on whether multilingual telephone lines were helpful. 

Some travelers felt they were helpful, and others felt that if the information 

is prerecorded, it is not effective. While New Jersey Transit does have a 

multilingual telephone line (not prerecorded), most of the respondents in 

this study were not aware of the service, which was likely due to a lack of 

advertising. Finally, LEP groups stated that Web sites were also not 

particularly helpful because many of the respondents did not have access 

to the Internet.24

24Liu, Mobility Information Needs of LEP Travelers, pp. 28-29.
Page 36 GAO-06-52 Language Access to Transportation Services

Costs May Not Be 

Burdensome at the Current 

Level of Activity, but They 

Could Escalate with 

Additional Languages and 

Services

On the basis of our site visit data, we determined that agencies generally 

did not believe that the costs for existing language access activities were 

burdensome.25 Many transit agencies believed that providing services to 

LEP populations makes sound business sense. Such agencies recognize 

that LEP populations represent a significant portion of both their current 

and their potential ridership. Thus, making services more accessible to LEP 

persons could increase ridership. For instance, officials at Austin’s Capital 

Metro told us that their outreach efforts to LEP communities has resulted 

in increased ridership and greater public support for the agency.

While several of the transit agencies we interviewed did not view LEP 

language access costs as burdensome, the majority of agencies were 

unable to provide much data on many of the costs associated with their 

LEP access services. Sometimes these costs were simply not tracked 

because they were spread out over several departments, or because LEP 

access activities were not separated from broader costs. The New Jersey 

survey of transit agencies also found little available data on costs, with only 

one-third of respondents sharing cost information.26 Of the respondents to 

that survey providing cost information, about one-half of them reported 

annual costs of between $10,000 and $30,000; one-quarter reported costs of 

under $5,000; and one-quarter reported costs greater than $100,000. 

Transit agencies and MPOs were able to avoid incurring substantial 

additional costs by utilizing existing staff. For instance, many agencies 

stated that rather than contracting out for interpreters at public meetings, 

they bring in bilingual staff members, use bilingual board members, or rely 

on community groups or individuals to bring their own interpreters as 

needed. A similar situation occurs in providing interpreters for customer 

service telephone lines. While 7 transit agencies have access to some form 

of a language line with formalized services, many agencies have operators 

who are bilingual or who will utilize various bilingual staff members 

25Several different cost components can be associated with efforts to provide access to 

public transit for LEP persons. These costs must be differentiated from costs that would 

ordinarily be experienced by an agency whether a service is provided in English or in 

another language. Extra costs borne by an agency that are directly attributable to LEP 

access activities include the following: outside translation and interpreter costs, cost 

differentials for developing and printing materials in other languages versus providing these 

services in English, the creation of translated pages on Web sites, premiums paid to bilingual 

employees, and software costs to provide multiple languages options at ticket machines. 

26Liu, Mobility Information Needs of LEP Travelers, p. 32.
Page 37 GAO-06-52 Language Access to Transportation Services

throughout their operations to field LEP calls when needed. In terms of 

printed documents and materials, many of the transit agencies and MPOs 

we visited have their translations done in-house using bilingual staff 

members. Often, translation is not part of these staff members’ official 

responsibilities, but it is done on a voluntary basis at no cost to the agency 

beyond the use of staff time. 

Although several transit agencies and MPOs did not report unduly 

burdensome costs, the cost of providing LEP access has the potential to 

increase significantly if agencies seek to undertake more comprehensive 

programs.27 As we previously discussed, many agencies rely on existing 

staff to do their translations of materials and to act as interpreters. Utilizing 

existing staff becomes more difficult when an agency attempts to provide 

access beyond just one or two languages. In that case, agencies would 

likely have to contract out for translation and translator services, or have to 

expend additional time and effort during the hiring process to find qualified 

candidates fluent in the languages desired. Contracting out for both 

translation and translator services can be costly. For example, the Capital 

Metro in Austin estimates that it spends between $10,000 and $15,000 a year 

for outside translations of materials. The Chicago Transit Authority stated 

that it spent over $1,100 for interpreters at four public hearings in 2004. 

Costs will also rise for agencies if they seek to make more comprehensive 

translated information about their services and programs available through 

multiple sources. For example, only 1 agency we visited had developed a 

comprehensively Web site. In addition to any translation costs incurred, 

developing fully translated Web sites is likely to require modifications to an 

agency’s Web site architecture, which has the potential to be costly. For 

instance, the Chicago Transit Authority estimated that the initial costs of 

translating its Web site into Spanish, Chinese, and Polish could potentially 

be between $74,000 and $99,000. In addition, the ongoing costs for 

maintaining the translated sites could also be substantial. Agency officials 

told us that the capability to update just the Spanish section of a translated 

Web site on a regular basis would require a new full-time employee and the 

purchase of additional software, costing an estimated $47,000 to $60,000 

27Cost considerations are one of the factors that federal agency guidance suggests agencies 

consider when determining what constitutes reasonable access. DOJ’s guidance to federal 

agencies states that the resources available to an agency may have an impact on the nature 

of the steps that recipients must take. Smaller recipients with more limited budgets would 

not be expected to provide the same level of services as larger recipients with larger 

budgets. 67 Fed. Reg. 41455, 41460 (June 18, 2002). 
Page 38 GAO-06-52 Language Access to Transportation Services

annually. In addition, providing language line service that covers multiple 

languages could raise costs significantly for transit agencies, depending on 

the usage of the line. Costs for language line services vary, depending on 

the provider as well as the language being translated, but generally costs 

per minute range from $1.00 to $1.50, which can add up to significant 

amounts. For example, the Chicago Regional Transportation Authority’s 

language line cost about $16,000 in 2004, and Access Services in Los 

Angeles spent $3,500 in the first 3 months of 2005. In addition, to the extent 

that agencies seek to provide printed materials in languages other than 

Spanish, there would be increased typesetting and formatting issues that 

would give rise to higher costs as well. This is especially true with 

languages using non-Roman alphabets. For example, officials at the Orange 

County Transportation Authority estimated that the cost of producing 

materials in Chinese would be significantly more than for Spanish 

materials. Finally, in terms of public outreach, a shift to more proactive 

strategies may lead to higher costs. Transit agencies and MPOs that take 

the initiative to actively reach out to various community groups and LEP 

populations would likely need to dedicate a greater amount of staff time 

and resources.

DOT Assists Grantees 

on Language Access 

Services through Its 

Guidance and Other 

Activities, but These 

Resources Are Not 

Often Accessed by 

Local Agencies

DOT’s LEP guidance provides grantees with a five-step framework for how 

to provide meaningful access to LEP populations, along with some 

information on how to implement such a framework; however, officials at 

the majority of the 20 transit agencies and 7 MPOs we visited were not 

aware of the LEP guidance. Of the agencies that were aware of the 

guidance, only 3 had changed their language access activities in response 

to it, and only 1 transit agency appeared to have fully implemented the fivestep framework. DOT and DOJ have also provided other types of assistance 

on language access services—such as workshops, a DOJ-sponsored 

interagency Web site, and other resources—but most of the transit 

agencies and MPOs we visited had not accessed these resources. Officials 

at transit agencies and MPOs we visited stated that training and technical 

assistance that is widely available, and specific to language access and how 

to implement DOT’s LEP guidance, could help them more effectively 

provide access to LEP populations. 
Page 39 GAO-06-52 Language Access to Transportation Services

DOT’s LEP Guidance 

Provides Steps to 

Meaningful Access, but DOT 

Took Limited Steps to Make 

Grantees Aware of 

Guidance

DOT’s 2001 LEP guidance outlines five steps funding recipients should take 

to provide meaningful access for LEP persons, including (1) conducting an 

assessment of the language groups within their service areas and the 

language needs of these groups; (2) developing and implementing written 

plans outlining their strategies for ensuring access to services for LEP 

populations; (3) making staff aware of the LEP access plan, training them, 

and providing them with the tools necessary to carry out the plan; (4) 

ensuring that language access services are actually provided in a consistent 

manner and that LEP populations are aware of these services; and (5) 

developing monitoring programs that allow agencies to assess the success 

of their LEP access programs and to identify needed modifications. The 

guidance gives some information on how to implement the framework and 

examples of promising practices. For example, the guidance lists 

components that a written plan should generally include, although it does 

not provide examples of such a plan. 

DOT made its guidance available to its funding recipients through the 

Federal Register, its Web site,28 and the DOJ interagency Web site; however, 

DOT headquarters officials did not distribute the guidance through any 

other direct method to ensure that grantees were aware of it, such as 

through a policy memorandum or other outreach to grantees. According to 

a DOT official, DOT relies on its operating agencies to make grantees 

aware of the guidance, and, in turn, these operating agencies may rely on 

regional representatives to make grantees aware of the guidance. In the 

areas we visited, however, FTA regional representatives had not 

disseminated the guidance or made grantees in their areas aware of the 

guidance. Staff turnover in DOT’s agencies, as well as in local transit 

agencies and MPOs, likely complicate agency awareness of the guidance, 

since newer employees may not be aware of documents issued years 

earlier. Although, according to a DOT official, DOT has not done much to 

reinforce awareness of the guidance, or grantees’ responsibilities under it, 

since its original publication in the Federal Register in 2001.

As a result, the majority of officials we visited during our site visits who are 

primarily responsible for implementing aspects of DOT’s guidance were not 

aware of the guidance. Some of the officials we visited who were aware of 

the guidance had not made significant changes in response to it. Rather 

28DOT’s guidance is available electronically on FTA’s Web site under “Transit Data & Info” 

and then “Title VI policy, Guidance & Procedures,” and through FHWA’s Civil Rights Office 

Web site under “Non-Discrimination.”
Page 40 GAO-06-52 Language Access to Transportation Services

than citing DOT’s guidance, officials at the transit agencies and MPOs we 

visited indicated that they provide language access activities in response to 

their customer base and demographics, as a result of the Environmental 

Justice initiative,29 or as a result of requests from community groups or 

board members. Officials at many transit agencies and MPOs we visited 

said they had been providing language access services for many years prior 

to the executive order and DOT’s guidance. Other officials indicated that 

they were not sure what their responsibilities were under the guidance. 

Of the 9 transit agencies and 3 MPOs we visited that were aware of DOT’s 

guidance, only 2 transit agencies and 1 MPO made changes to their 

languages access activities as a result. Examples of agency responses to 

the guidance include the following:

• The Alameda-Contra Costa Transit District developed an inventory of its 

language access activities, with several proposals for improving 

language access services that are now being implemented.

• The Metropolitan Transportation Commission in the San Francisco Bay 

Area indicated that, while it had not significantly changed its practices 

as a result of the guidance, it had increased its efforts.

• The Chicago Transit Authority formed a committee to examine LEP 

issues after the release of the guidance in 2001. This committee 

determined the languages spoken in its service area from Census data 

and has discussed the idea of implementing a survey to determine what 

language needs exist. No current plan or timeline for developing or 

implementing the proposed survey exists. 

29Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations,” issued on February 11, 1994, directed every 

federal agency to make environmental justice part of its mission by identifying and 

addressing the effects of all programs, policies, and activities on “minority populations and 

low-income populations.” DOT’s environmental justice initiatives accomplish this goal by 

involving the potentially affected public in developing transportation projects that fit 

harmoniously within their communities without sacrificing safety or mobility. There are 

three fundamental environmental justice principles, which are to (1) avoid, minimize, or 

mitigate disproportionately high and adverse human health and environmental effects, 

including social and economic effects, on minority populations and low-income 

populations; (2) ensure the full and fair participation by all potentially affected communities 

in the transportation decision-making process; and (3) prevent the denial of, reduction in, or 

significant delay in the receipt of benefits by minority and low-income populations.
Page 41 GAO-06-52 Language Access to Transportation Services

Officials from the California, North Carolina, and Texas state departments 

of transportation reported that they had begun to monitor their small urban 

and rural grantees’ LEP activities as a result of the executive order and 

DOT’s guidance. As a result, some materials have been provided to grantees 

about their responsibilities under the guidance.30

Some of the transit agencies and MPOs we visited told us that technical 

assistance and information would be helpful in implementing DOT’s 

guidance, and 1 transit agency cited a lack of funds and time to conduct an 

assessment of language access needs and to provide and evaluate language 

access activities. For example, an MPO in North Carolina said it would 

benefit from the ability to easily access practical resources on language 

access services for LEP persons. In addition, agency officials at a transit 

agency in California told us that an example of a needs assessment—with 

estimates of the cost to conduct one and effective ways to outreach to LEP 

persons—would be very helpful. A DOT official told us that, in anticipation 

of issuing DOT’s revised guidance, additional training and assistance was 

being considered within DOT. 

30The California Department of Transportation has developed a written department policy 

for LEP persons. The intent of the policy is to ensure departmental employees are aware 

that LEP persons shall be provided meaningful access to the department’s programs, 

activities, and services that are normally provided in English. In addition to the draft policy 

for LEP, the department is in the process of finalizing “standard” LEP office procedures for 

the various program areas and districts to use. Finally, the department developed an LEP 

training module, which includes requirements under state law (Dymally-Alatorre Bi-lingual 

Services Act of 1973); federal law (Title VI of the Civil Rights Act of 1964); and Executive 

Order 13166, “Improving Access to Services for Persons with Limited English Proficiency.” 

This training module will be used to inform departmental staff of LEP requirements and 

assist them to ensure that the regulatory requirements are met. Process reviews of program 

areas will be conducted in conjunction with Title VI reviews to determine the level of 

compliance; corrective action, if necessary; and best practices.
Page 42 GAO-06-52 Language Access to Transportation Services

Other Federal Resources 

Address Language Access 

Issues to Varying Degrees, 

but They Are Not Frequently 

Used by Grantees

DOT’s Workshops at 

Conferences and Federal Web 

Sites Provide Some Assistance 

on DOT’s LEP Guidance

FTA and FHWA have hosted a few workshops at annual conferences31 that 

have provided assistance on how to implement portions of the framework 

described in the guidance.32 Presentations held by FTA and FHWA reviewed 

the LEP executive order, and DOT’s LEP guidance, and provided workshop 

participants with real-world LEP information, including how to identify 

LEP populations in their service areas. For example, workshops included 

the following:

• Strategies for Complying with FHWA LEP Requirements, was held at the 

Southern Transportation Civil Rights Conference in Orlando in August 

2005.33 This training identified strategies to ensure that LEP persons 

have access to programs, services, and information through the 

application of DOT’s guidance. In addition to this presentation, a “train 

the trainer” curriculum was developed regarding LEP awareness.34

Training attendees were provided with a manual with resources on 

providing language access, which included DOT’s guidance, language 

31Since 2003, FTA and FHWA have held workshops that specifically address language issues 

in the context of the guidance at conferences held by the Conference of Minority 

Transportation Officials, the American Association of State Highway and Transportation 

Officials, and the Community Transportation Association of America.

32The North Carolina State Department of Transportation became aware of DOT’s LEP 

guidance through a 2-day workshop on Civil Rights and Environmental Justice, which was 

given by FHWA at the department’s request.

33According to the FHWA official, the presentation should soon be available on FHWA’s Civil 

Rights Web site. Additionally, this official told us the presentation will be shared with others 

via FHWA’s internal Community of Practice Web site.

34This curriculum was developed for Maryland state employees to assist them in 

implementing a proposed law on language access. The Maryland State Senate Bill requires 

state departments, agencies, or programs to take reasonable steps to provide equal access 

to public services for LEP individuals, which includes the translation of forms and 

documents ordinarily provided to the public into any language spoken by any LEP 

population that constitutes 3 percent of the overall population within the geographic area 

served by a local office of a state department, agency, or program.
Page 43 GAO-06-52 Language Access to Transportation Services

identification flash cards, language statistical data, language assistance 

self-assessment tools, and commonly asked questions and answers. 

• Fair Transportation: Incorporating Equity Concerns into Transit 

Planning and Operations, presented to the Conference of Minority 

Transportation Officials by FTA’s Office of Civil Rights, occurred in July 

2005. This presentation discussed the changing demographics and 

growing multicultural nature of the American population and the 

increase in the number of LEP persons nationwide. FTA staff 

summarized the requirements of DOT’s LEP guidance, and 

recommended that transit agencies incorporate attention to the needs of 

LEP persons into elements of their routine planning and operations, 

such as their complaint procedures, marketing, customer surveys, and 

community outreach. 

• LEP: A Lesson in Redefining Public Involvement was given at the 2003 

Conference of Minority Transportation Officials National Meeting and 

Training Conference. This presentation provided information about the 

LEP executive order and DOT’s guidance, and used real-world examples 

to illustrate the complications an agency may face as a result of not 

providing information to LEP populations during the planning process. 

The presentation also defined compliance with the LEP executive order 

by listing important components in DOT’s guidance (i.e., a needs 

assessment, a written language assistance plan, language assistance, 

and monitoring). 

• How to Identify LEP Populations in Your Locality was given by FHWA at 

the American Association of State Highway and Transportation 

Officials’ 2004 Civil Rights Conference. This presentation also provided 

information on the LEP executive order; DOT’s guidance; and specific 

information about what resources can be used to identify LEP 

populations, which is the first step of conducting a needs assessment. 

For example, the presentation highlighted using Census and state 

departments of education data to identify the size and location of LEP 

populations. This presentation is available on FHWA’s Civil Rights Web 

site. 

Besides offering workshops, DOT also participates in the Federal 

Interagency Working Group on Limited-English Proficiency, which 

provides resources to federal grantees mainly through its Web site,

http://www.lep.gov. The resources available on the Web site are generally 

not specific to transportation, with the exception of DOT’s LEP guidance 
Page 44 GAO-06-52 Language Access to Transportation Services

and a multilingual video on using public transit, “Making Public Transit 

Work for You,” which was produced by the Contra Costa Commute 

Alternative Network. The Web site, which is maintained by DOJ, serves as a 

clearinghouse by providing and linking information; tools; and technical 

assistance about LEP and language services for federal agencies, recipients 

of federal funds, users of federal programs and federally assisted programs, 

and other stakeholders. While most of the information on the Web site is 

not specifically about transportation, some of it could be applicable to 

transit agencies. For example, the Web site contains a variety of tools—

including a self-assessment—to help local agencies assess their current 

language services and plan for the provision of additional language 

assistance to LEP individuals. The Web site also provides an overview of 

how to develop a language assistance plan, and it contains performance 

measures, such as a measure of the extent of ongoing feedback from the 

community, in order to evaluate the effectiveness of LEP activities. In 

addition, there is a video on the Web site regarding LEP access issues that 

could be used in training for customer service personnel at transit 

agencies. FTA’s Title VI Web page provides a link to this Web site.

Other DOT Resources Have Few 

Language Access Activities or 

Touch on Language Issues in a 

Broader Context 

FTA and FHWA have two peer-exchange programs through which local 

agencies can share innovative or effective practices on various topics that 

have sometimes included language access. FTA’s peer-exchange program, 

called Innovative Practices for Increased Ridership, and FTA and FHWA’s 

collaborative peer-exchange program, called the Transportation Planning 

Capacity Building Program, allow agencies to easily share information over 

the Internet. FTA’s Innovative Practices Web site serves as a central 

information resource for innovative strategies on various topics. Innovative 

practices are submitted by transit organizations and reviewed by FTA, and 

these practices are then made available for other transit organizations to 

search records, review innovations, and potentially implement similar 

programs. A search of FTA’s Innovative Practices Web site revealed some 

assistance on language access issues. In one example, a transit agency in 

Maine created a multilingual brochure that provided basic information 

about riding its bus service in eight languages, including Spanish, SerboCroatian, Russian, Khmer, Somali, Vietnamese, French, and English, and 

plans to translate the brochure into six more languages, including Farsi, 

Arabic, Acholi, Swahili, Chinese, and Bulgarian. The transit agency credits 

this effort with increasing its ridership. 
Page 45 GAO-06-52 Language Access to Transportation Services

The Transportation Planning Capacity Building Program35 provides 

resources to local agencies through its Web site, where users can search 

various topics to find out if any other agency has posted helpful 

information on those topics. LEP resources are not directly available 

through an explicit link on this Web site. However, a search of the 

program’s Web site under Title VI and Environmental Justice issues 

revealed some assistance on language access. For example, the materials 

from a workshop called Identifying and Engaging Low Literacy and Limited 

English Proficiency populations in the Transportation Decision-making 

Process, which was held in Atlanta in May 2004, was made available to 

users on the Web site. The workshop refers to the LEP executive order and 

describes innovative and effective practices that some agencies have 

employed to improve awareness among communities and transportation 

planning agencies of the existence of low-literacy and LEP populations in 

their areas.

FTA and FHWA also provide federal grantees with training and technical 

assistance—through the National Transit Institute (NTI) and the National 

Highway Institute (NHI), respectively—that address language access issues 

to some extent in training on other subjects, such as public participation in 

the transportation planning process. Funded by grants from FTA, NTI 

provides training, education, and clearinghouse services in support of 

public transportation. Representatives from NTI identified five training 

courses in which language issues were discussed in the broader context of 

other issues. 36 In addition, NTI is developing a course for transit employees 

that will specifically address cross-cultural communications, including tips 

for overcoming language barriers, such as speaking slowly, being patient, 

and not using slang words. NHI also provides training, resource materials, 

and technical assistance to the transportation community, although, like 

NTI training, language issues are addressed as they relate to the course 

content. An official from NHI identified two training courses in which 

language issues were discussed. An example is NHI’s course called 

Fundamentals of Title VI/Environmental Justice, in which LEP issues are 

woven into the course materials. The training gives examples of outreach 

35The Transportation Planning Capacity Building Program is designed to help decision 

makers, transportation officials, and staffs resolve the increasingly complex issues they face 

when addressing transportation needs in their communities.

36In addition to the five courses identified, 1 transit agency in North Carolina cited an NTI 

training course, entitled Customers, Conflicts, and You: A Transit Operators Guide to 

Problem Solving, in which language was discussed.
Page 46 GAO-06-52 Language Access to Transportation Services

done by various agencies, which includes providing meeting materials and 

flyers in Spanish. Another course, entitled Public Involvement Techniques 

for Transportation Decision Making, describes the importance of including 

LEP populations in the planning process; provides suggestions on effective 

ways to reach out to LEP populations, such as through community groups 

and informal meetings; and outlines ways to continue communication with 

LEP groups once a connection has been established. For example, the 

training states that providing translated materials and interpreters at 

meetings is essential in reaching non-English speakers. NHI and NTI 

representatives told us that they are working to combine their relevant 

training courses on public involvement in the transportation planning 

process into one course.

Other Available Federal 

Resources Are Rarely Used by 

Grantees

The majority of transit agencies and MPOs we visited did not access the 

federal resources previously discussed because many officials were 

unaware that these resources exist. Only a few agencies we visited had 

reported attending workshops held at annual conferences on language 

access issues,37 and no agency we met with had reported accessing 

information available through http://www.lep.gov. Furthermore, statistics 

on the number of Internet users that accessed LEP resources on the Webbased peer-exchange programs indicate that these resources are not 

accessed often in comparison to other resources on those Web sites. A few 

transit agencies we visited were aware of or had accessed the NTI training 

entitled Public Involvement in Transportation Decision-Making, which 

includes a section on ensuring that nontraditional participants—that is, 

minority, low-income, and LEP populations—are included in the public 

involvement process associated with transportation planning. 

37We did not review overall attendance at these workshops to determine the extent to which 

this information was accessed by transit agencies nationwide, but rather we focused on 

whether the agencies we visited were aware of the resources that DOT provides.
Page 47 GAO-06-52 Language Access to Transportation Services

Three Review 

Processes Provide 

Limited Monitoring of 

Language Access 

Activities, and Criteria 

for Finding a 

Deficiency Are 

Inconsistent

Language access activities of transit agencies and MPOs are monitored 

through three review processes—FTA’s Title VI compliance reviews, FTA’s 

triennial reviews, and planning certification reviews conducted jointly by 

FTA and FHWA (described in table 1). However, these reviews do not fully 

take into account Executive Order 13166 or DOT’s LEP guidance, and the 

criteria for finding a deficiency with regard to providing language access 

are inconsistent. 

Table 1: FTA and FHWA Reviews

Source: GAO.

Type of review Description and scope 

Title VI compliance 

review

A Title VI compliance review is conducted to determine if the grantee’s required efforts under Title VI of the Civil 

Rights Act of 1964 are represented to the Federal Transit Administration (FTA). This review lasts 2 to 3 days and 

assesses implementation of Title VI programs in areas such as general reporting requirements, service 

standards and policies, and language access. This review covers each agency’s policies, procedures, and 

record keeping related to Civil Rights and Title VI.

Triennial review The triennial review is a periodic process review that is conducted at least once every 3 years for each formula 

grant recipient. The results of the triennial review are integrated into FTA’s grant management functions and 

ultimately serve as the basic review of FTA’s comprehensive oversight program. Although it is broad in scope, 

the triennial review is the only FTA review that is statutorily mandated.

Planning certification 

review

The planning certification review occurs at least once every 4 years in all Transportation Management Areas, 

which are metropolitan areas that have a population that exceeds 200,000 people. Unlike the aforementioned 

reviews, the planning certification review is conducted jointly by FTA and the Federal Highway Administration 

(FHWA). The objective of this review is to enhance the effectiveness of federal oversight of the transportation 

planning process. The planning certification review process includes a desk review, on-site interviews with all 

participants in the planning process, and input from the public. The review concludes with a final report of 

findings and recommendations, which is intended to provide an overview of the planning process and identify 

areas where FTA and FHWA need to provide guidance or direction to the process.
Page 48 GAO-06-52 Language Access to Transportation Services

The Title VI compliance review 38—an in-depth review of a limited number 

of transit agencies, MPOs, and state DOTs—does not assess language 

access activities using the LEP guidance, but rather assesses them using 

guidelines in an FTA circular, which asks agencies to describe the language 

access they provide.39 However, the circular does not provide agencies with 

a framework, and does not have much specificity regarding what agencies 

should provide in terms of language access. FTA officials told us that the 

circular is used for the compliance review because it is a requirement for 

agencies, while agencies are not required to implement all aspects of DOT’s 

LEP guidance. The officials further stated that they have considered 

including more aspects of DOT’s guidance in the compliance review. 

We reviewed Title VI compliance reviews completed between 2002 and 

2004 and found that the scope of these reviews of language access activities 

varied, and may not assess local agencies’ language activities across the 

entire breadth of communication strategies previously outlined in this 

report. For example, in one review, an agency was found deficient because 

it did not have safety and emergency information translated, yet in other 

reviews it was unclear whether safety and emergency information was 

included in the scope of the review. Furthermore, the scope of the 

multilingual communications portions of the Title VI compliance reviews 

has varied on the basis of the primary objective of the endeavor. Some of 

these reviews considered only the extent to which language assistance was 

provided to persons wanting to involve themselves in the transit system’s 

planning and decision-making processes because the scope of the reviews 

focused solely on these processes. Other reviews evaluated only the extent 

to which language assistance was provided to persons wanting to use the 

38Since 2002, FTA has conducted roughly six compliance reviews per year of transit 

providers, state DOTs, or MPOs, final reports from these reviews are available on FTA’s Title 

VI Web page. See http://www.fta.dot.gov/16241_ENG_HTML.htm. FTA identifies recipients 

for review on the basis of complaints against the recipient, media reports, recommendations 

of regional civil rights officials, outstanding findings on past triennial reviews, and FTA’s 

desire to review both smaller and larger grantees in areas around the country.

39Recipients of FTA funding assistance are subject to the Title VI compliance conditions 

associated with the use of these funds pursuant to FTA Circular 4704.1, “Title VI Program 

Guidelines for Grant Recipients,” dated July 26, 1988; Part II, Section 117(a) of the FTA 

Agreement; and FTA Circular 4702.1, “Title VI Program Guidelines for Federal Transit 

Administration Recipients,” dated May 26, 1988. The program guidelines of FTA Circular 

4702.1 define the components that must be addressed and incorporated in the recipients’ 

Title VI Program and are the basis for the selection of compliance elements that are 

reviewed in FTA discretionary reviews.
Page 49 GAO-06-52 Language Access to Transportation Services

transit system. Table 2 provides examples of deficiency findings related to 

language access from these Title VI reviews. 

Table 2: Language Access Deficiencies Found through Title VI Compliance Reviews

Source: GAO review of Title VI compliance reviews, 2002-2004.

In March of 2003, FTA’s Office of Civil Rights conducted a pilot Title VI 

compliance review of the Brownsville Urban System in Texas, specifically 

looking at the extent to which the agency had implemented DOT’s LEP 

guidance. This pilot was initiated as part of a refocusing of Title VI 

compliance reviews on more specific issues within Title VI, including 

multilingual communications, fare increases, service changes, and 

equitable allocation of resources. Brownsville was selected by FTA’s Office 

of Civil Rights for the pilot assessment for multilingual communication 

because of its large Spanish-speaking community.40 The assessment 

guidance used in the pilot incorporated sections of DOT’s guidance in 

Agency Type of review Finding Recommendation Agency response

Chicago 

Transit 

Authority

Limited scope 

review – Review of 

Service/Fare 

Change

The agency did not 

adequately 

communicate 

information at public 

meetings in other 

languages.

The agency should improve its 

community outreach efforts to 

ensure that minority residents 

are heard.

The agency pledged to establish a 

public participation process that 

increases the number of public 

meetings and outreach to community 

organizations.

Metro St. 

Louis

Limited scope 

review – Review of 

Service/Fare 

Change

Review found that 

language access 

considerations may not 

have adequately been 

taken into account.

Review recommended that the 

agency evaluate whether there is 

a need for considering limited 

English-proficient (LEP) persons 

when disseminating information.

The agency indicated that it would 

prepare a written assessment of the 

need to address LEP needs. The 

assessment will include targeted 

surveys of operators and customers on 

routes known to serve immigrant 

populations, as well as interviews with 

advocacy groups, community groups, 

and human service agencies that serve 

immigrant populations.

New York 

City Transit

Full Title VI 

compliance review

Sampling of vehicles 

and facilities failed to 

confirm the consistent 

use of Spanish in safety 

and emergency 

evacuation procedures.

Within 90 days, the agency must 

submit to the Federal Transit 

Administration (FTA) 

documentation that a Policy for 

Translating Customer 

Information Materials has been 

finalized and implemented.

The agency submitted its draft policy, 

which indicated it would translate safety 

notices into Spanish, and FTA accepted 

it. The agency also provided several 

examples in its quarterly progress 

reports of safety messages translated 

into Spanish.

40FTA’s Office of Civil Rights informed us that they have plans to conduct a similar 

assessment of another entity in fiscal year 2006.
Page 50 GAO-06-52 Language Access to Transportation Services

addition to the multilingual facilities section of the FTA circular used in 

other Title VI compliance reviews. The assessment focused on whether the 

Brownsville system had ensured meaningful access to LEP persons by 

assessing 11 different aspects of providing greater access to LEP persons. 

For example, the review focused on whether the agency had a needs 

assessment and a written language assistance plan; the agency’s provision 

of language services (e.g., oral interpretation; written translations; and 

alternative, nonverbal methods); and its provision of language access to its 

grievance or complaint procedures. Brownsville was found deficient in 5 of 

the 11 areas, as shown in table 3.
Page 51 GAO-06-52 Language Access to Transportation Services

Table 3: Results of the Pilot LEP Review of the Brownsville Urban System in Texas

Source: GAO review of the Brownsville Pilot Title VI Assessment on Language Access.

FTA’s Office of Civil Rights has also recently developed an initiative that 

focuses on fare and service changes, but FTA’s advice to agencies related to 

this initiative has not always been consistent. While this initiative is based 

on the Executive Order on Environmental Justice, it does include an LEP 

component. In 2004, FTA developed and disseminated a self-assessment 

(also posted on the FTA’s Title VI Web site) to about 20 transit agencies 

considering fare and service changes. This assessment included questions 

about the public involvement process and asked the transit agency whether 

it believed outreach to the LEP population was warranted, and, if so, what 

steps the transit agency had taken or was planning to take to inform its LEP 

population about the service or fare changes and to offer this population 

the chance to comment on the changes. The majority of the agencies that 

returned this self-assessment reported that they had taken steps to reach 

out to their LEP populations using methods similar to those previously 

noted in this report, such as posting information about the upcoming fare 

Area examined Result of review Recommendation

Needs assessment Deficiency - overall assessment not conducted Identify other language needs in the 

community

Assessment of linguistically isolated 

populations

Deficiency - assessment not conducted Identify linguistically isolated populations 

during overall needs assessment

Identification of barriers Deficiency - not conducted Identify communication barriers during 

overall needs assessment

Written language assistance plan Deficiency - language assistance plan not in 

writing

Draft written language assistance plan

Availability of multilingual 

communications

Deficiency - reasonable efforts to provide 

multilingual communications; however, several 

items found only in English

Translate the hours of operation and 

remaining information on the route 

schedules and system maps into Spanish

Staff training No deficiency - staff aware of and understand 

language assistance plan

None

Special language assistance No deficiency - adequate and effective methods 

for notification of language assistance

None

Monitoring No deficiency - regular oversight provided Use passenger survey for additional 

feedback

Types of language services No deficiency - adequate mix of oral interpretation 

and written translations

Consider the use of alternative, nonverbal 

methods of communication

Grievance or complaint procedures No deficiency - adequate complaint procedure in 

place

Put complaint procedure in writing

Limited English-proficient 

community outreach and education

No deficiency - adequate community outreach None
Page 52 GAO-06-52 Language Access to Transportation Services

increases in multiple languages in vehicles and stations, advertising the 

changes in other-language newspapers, and including interpreters at public 

meetings established to discuss the changes. Several of the transit agencies 

responding to this initiative stated that they had not engaged in LEP 

outreach because the number and proportion of LEP persons in their 

service areas were very small (i.e., less than 1 percent). For 1 agency, FTA 

encouraged the agency to conduct a further assessment of the LEP 

population, even though the agency reported that only 119 residents in its 

service area (less than 1⁄2 of 1 percent) did not speak English well. Yet, in 

another location, where the agency reported that only 1⁄2 of 1 percent of the 

service area population was LEP, FTA encouraged the transit agency to 

monitor demographic trends to determine whether limited English 

proficiency may become more relevant in the future, rather than conduct a 

further assessment. 

Another of the review processes, the triennial review, looks at whether 

transit agencies that receive Urbanized Area Formula Grants have 

complied with statutory and administrative requirements in 23 areas, one 

of which is Title VI.41 Because this review covers a wide variety of activities 

and federal requirements, it is not as in-depth with regard to Title VI as Title 

VI compliance reviews. However, the triennial review serves as the basic 

review of FTA’s oversight program. Under the Title VI section of the 

triennial review, specific questions make reference to DOT’s LEP guidance: 

“Has the grantee assessed and addressed the ability of persons with limited 

English proficiency to use transit services? Are schedules and other public 

information provided in languages other than English? If yes, what other 

languages are provided?” In the triennial review, the grantee is found 

deficient only if a complaint has been made and the grantee has not 

conducted an assessment of the population and the need for LEP materials. 

However, several community and advocacy groups we met with indicated 

that there may be language barriers to making a complaint, and, as we 

previously discussed, there may be different cultural or social norms that 

preclude LEP persons from making complaints (i.e., some persons may feel 

41The triennial review focuses on compliance with statutory and administrative 

requirements, and, should the review reveal a deficiency on the part of the grantee to 

comply with Title VI—or any other of the 23 oversight topics—further and more detailed 

reviews will follow to ensure continued adherence to federal standards. In addition, 

grantees found not to be in compliance may have their funding reduced or eliminated. FTA 

conducts this review with some of its own personnel, but it also uses several contractors to 

complete the review.
Page 53 GAO-06-52 Language Access to Transportation Services

that it is not their place to question the government, or may feel 

uncomfortable doing so). 

Because a deficiency is found only if a complaint has been made and the 

agency has not conducted an assessment, findings of deficiencies are rare; 

although our case studies and the New Jersey survey of transit agencies 

suggest that most agencies have not conducted a language needs 

assessment.42 We reviewed 34 triennial reviews conducted in fiscal year 

2005 that identified one or more deficiencies in the area of Title VI and 

found only one deficiency related to LEP. In 2005, the Fayetteville Area 

System of Transit was found deficient for not conducting an assessment of 

the extent to which there are LEP persons in its service area. Within 90 

days, the agency was to provide FTA with documentation that it had 

conducted an LEP assessment and with information on the steps it would 

take to address any needs identified.

The third of the three review processes that monitor language access 

activities is the planning certification review, which looks at how well state 

and regional planning processes comply with DOT planning regulations.43

This review is conducted jointly by FTA and FHWA and is also not as indepth with regard to Title VI as Title VI compliance reviews. One section of 

the review guidelines is directed at LEP issues with regard to public 

participation in the planning process, but the review does not incorporate 

the LEP guidance. The section states that agencies should “if necessary, 

make available communications for the hearing impaired and provide sign 

and foreign language interpreters.” It is not clear what constitutes a 

deficiency in these reviews, and during the past 2 years, there have been no 

deficiency findings regarding language.

In addition to the review processes, FTA investigates Title VI complaints 

filed by the public alleging national origin discrimination against LEP 

persons. These investigations focus on whether a recipient has taken 

reasonable steps to provide meaningful access to LEP persons. However, 

42Liu, Mobility Information Needs of LEP Travelers, p. 32.

43DOT prepares review guidelines for reviewers at the regional level. These reviewers may 

modify their review questions on the basis of regional differences. Every state and regional 

planning process is reviewed every 3 years. Of the approximately 400 MPOs across the 

country, only the largest one-third of them (in areas with populations over 200,000) is 

subject to formal certification. The remaining agencies are required to self-certify. Over a 

3-year period, about 130 to 140 regional planning processes are reviewed.
Page 54 GAO-06-52 Language Access to Transportation Services

FTA has received only one complaint related to language access to date. 

The complaint—which was made by West Harlem Environmental Action, 

Inc.,44 against New York City Transit in November 2000—stated that no 

opportunity had been given for community groups to comment on New 

York City Transit’s capital plan to construct additional bus parking facilities 

next to an existing bus depot. The complaint further stated that the capital 

plan was not published in Spanish and no monolingual Spanish-speaking 

resident of northern Manhattan was afforded the opportunity to comment 

on the capital plan. New York City Transit noted that since Executive Order 

13166 and the LEP guidance were issued after the development of its 2000-

2004 capital program, there was no requirement to issue the plan in any 

language other than English at that time. FTA responded that although the 

executive order and the LEP guidance were issued subsequent to the 

issuance of the plan, New York City Transit should have provided language 

access under its 1988 Circular on Multilingual Facilities. In resolving the 

complaint, FTA requested (1) copies of Spanish translations of public 

hearing notices and summaries of the capital program and (2) a report on 

what steps New York City Transit had taken to involve the public, including 

minority, low-income, and LEP populations, in its 2005-2009 capital 

planning process. FTA closed its investigation of this complaint in letters of 

finding transmitted in January 2005.

Conclusions Transit agencies and MPOs across the country are providing a wide variety 

of language access services. Determining and providing reasonable and 

effective language access to transportation services, however, is not a 

clear-cut matter. To do so, an agency must have a strong understanding of 

the size and location of the LEP community in its area as well as the 

information needs of this community, although such assessments are rarely 

done. The agency must then deal with a whole host of issues, such as 

determining which language access services to provide and in what 

quantity, how translations are to be accomplished, where such materials or 

services are best distributed, and how such materials and services are best 

publicized to the LEP communities. For agencies in very diverse areas, the 

challenges grow exponentially. Specifically, some of the questions they may 

need to address are as follows: How many languages should materials and 

services be translated into? Is there a threshold with regard to the size or 

44West Harlem Environmental Action, Inc., is a nonprofit, community-based, environmental 

justice organization dedicated to building community power to fight environmental racism 

and improve environmental health, protection, and policy in communities of color.
Page 55 GAO-06-52 Language Access to Transportation Services

proportion of different language groups before translations should be 

provided? Will translated signs be too complex for transit users to 

effectively use? Will the costs of translations, telephone, and Web services 

be burdensome, given the relatively light use some of these services may 

receive? Furthermore, providing language access is just one part of a larger 

communication strategy for these agencies, which can include determining 

how to provide useful information in English, how to communicate with 

the hearing or sight impaired, or how to deal with communication to 

persons with cognitive disabilities. One clear need in all of these instances 

is for agencies to outreach to these various communities and work in 

partnership to determine and meet a variety of information needs. 

DOT’s LEP guidance, and many of the available federal resources, can 

provide some assistance to transit agencies and MPOs when facing these 

challenges and making decisions about the level of language access to 

provide; however, the absence of local agency awareness of the existence 

of these resources limits their usefulness. In addition, for some transit 

agencies and MPOs, the available assistance was not effective in helping 

them answer some of the difficult questions previously outlined, because 

the assistance does not provide much information on what a good language 

and needs assessment contains, or how one is done. It also does not 

provide templates or examples of effective language access plans, nor does 

it provide much help in determining how to monitor and judge the 

effectiveness of agencies’ language access activities. Given the lack of data 

available on the effectiveness of services, the availability of such assistance 

takes on greater importance. More direct dissemination of the LEP 

guidance and available assistance, and the development of additional 

assistance related to conducting assessments, developing plans, and 

monitoring the effectiveness of language access activities could help 

connect local agencies with information and resources that may help them 

improve access to their services for LEP persons. 

While complaints concerning language access are rare, transit agencies’ 

and MPOs’ language access efforts are often perceived by community 

groups to be lacking in certain areas, particularly with regard to the 

inclusion of such communities in decision-making processes, thus opening 

up the potential for further complaints against these agencies for not 

providing reasonable language access. At present, however, monitoring and 

oversight activities conducted by FTA and, to a lesser extent, FHWA, are 

not likely to remedy perceived gaps in the provision of language access, 

due to the inconsistencies in scope and criteria for what constitutes a 

deficiency. For example, one of the chief complaints of community groups 
Page 56 GAO-06-52 Language Access to Transportation Services

is the lack of involvement of LEP communities or the community groups 

that represent them, in decision-making processes; however, planning 

certification reviews do not look at involvement per se, but rather they 

focus on whether interpreters were provided at public meetings “if 

necessary.” Furthermore, FTA’s pilot review of language access, which used 

DOT’s LEP guidance, revealed several deficiencies that would not have 

been found under current review processes, and these deficiencies can 

commonly be found across countless numbers of agencies. It is important, 

though, to consider that findings of deficiency, such as those found under 

the pilot review, do not necessarily indicate that an agency has been 

discriminatory. Nonetheless, further incorporation of key aspects of DOT’s 

LEP guidance in existing review processes and consistent criteria for what 

constitutes a deficiency could help transit agencies and MPOs understand 

their responsibilities under the executive order and DOT’s LEP guidance 

and lead to improved services for LEP persons. 

Recommendations for 

Executive Action

To improve awareness and understanding of DOT funding recipients’ 

responsibilities to provide language access services, we recommend that, 

upon final issuance of DOT’s LEP guidance, the Secretary of the 

Department of Transportation ensure that the guidance is distributed to all 

DOT funding recipients through a policy memorandum or other direct 

methods and direct regional personnel to make grantees in their areas fully 

aware of the existence of the guidance, and of grantee responsibilities 

under the guidance. 

To enhance and improve transit agencies’ and MPOs’ language access 

activities, we recommend that the Secretary, when issuing DOT’s revised 

LEP guidance, take the following two actions:

• Provide additional technical assistance, such as templates or examples, 

to aid these agencies in developing assessments of the size, location, 

and needs of the LEP population; plans for implementing language 

access services; and evaluations of the effectiveness of agencies’ 

language access services.

• Publicize the availability of existing federal resources on LEP issues, 

including workshops, http://www.lep.gov, peer-exchange programs, and 

available training to transit agencies and MPOs, and make these 

resources easily accessible through an explicit link to LEP Assistance 

on the Transportation Planning Capacity Building Program’s Web site.
Page 57 GAO-06-52 Language Access to Transportation Services

To ensure that transit agencies and MPOs understand their responsibilities 

to provide language access, and to ensure that they are providing adequate 

language access to their services and their transportation planning and 

decision-making processes, we recommend that the Secretary more fully 

incorporate the revised LEP guidance into current review processes by 

taking the following three actions: 

• Include questions on whether agencies have conducted assessments, 

have language access plans, and have evaluation and monitoring 

mechanisms in place in Title VI compliance reviews and triennial 

reviews. 

• Include more specific questions regarding language access to the 

planning process and involvement of LEP communities in planning 

certification reviews.

• Establish consistent norms for what constitutes a deficiency in the 

provision of language access across and within these review processes, 

ensuring that what constitutes a deficiency could directly lead to lesser 

service for LEP persons or complaints against the agency.

Agency Comments We obtained comments on a draft of this report from DOT officials who 

generally agreed with the findings and recommendations in the report. 

These officials also provided technical clarifications, which we 

incorporated in the report as appropriate. In particular, the officials said 

that DOT is already planning to take actions to address some of our 

recommendations, including ensuring that its revised LEP guidance is fully 

and appropriately distributed, and enhancing its training and technical 

assistance to grantees. 

We also provided DOJ with an opportunity to comment on segments of the 

report that pertain to DOJ processes and policies. DOJ provided technical 

clarifications, which we incorporated in the report as appropriate.

We are sending copies of this report to the appropriate congressional 

committees and to the Secretary and other appropriate officials of the 

Department of Transportation. We will also make copies available to others 

upon request. The report will be available at no charge on the GAO Web site 

at http://www.gao.gov. In addition, translated summaries of this report in 
Page 58 GAO-06-52 Language Access to Transportation Services

Spanish, Chinese, Vietnamese, and Korean will be available at no charge on 

the GAO Web site at http://www.gao.gov/special.pubs/translations.

If you or your staff have any questions about this report, please contact me 

at (202) 512-2834 or at siggerudk@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix III.

Sincerely yours, 

Katherine Siggerud

Director, Physical Infrastructure
Page 59 GAO-06-52 Language Access to Transportation Services

Appendix I

Scope and Methodology AAppenednxidexiIs

To determine the types of language access services that transit agencies 

and metropolitan planning organizations (MPO) provide to limited Englishproficiency (LEP) populations, we visited seven metropolitan statistical 

areas in Arkansas, California, Illinois, North Carolina, and Texas. We used 

U.S. Census Bureau data to select site visit locations, on the basis of the 

size and proportion of the LEP population, the number of languages 

spoken, the growth of the LEP population, and the extent of public transit 

use, to capture a variety of different circumstances agencies may face in 

providing language access services. We eliminated from our site visits areas 

that had recently had in-depth reviews by the Federal Transit 

Administration (FTA), as well as agencies that had been highlighted in a 

recent report for best practices in providing LEP access, to broaden the 

limited amount of research and data available in this area. Notable areas 

eliminated from our potential site visits for these reasons included New 

York, New York; Washington, D.C.; Portland, Oregon; and Seattle, 

Washington.1

 The relevant statistics for the seven areas we visited are 

presented in table 4. 

Table 4: Census Data on Language Ability and Transit Use for Seven Site Visit Locations

1

For more information on the specific language access activities of the main transit agencies 

in these four areas, see Dr. Rongfang (Rachel) Liu, Mobility Information Needs of Limited 

English Proficiency (LEP) Travelers in New Jersey (December 2004). Dr. Liu prepared this 

study for the New Jersey Department of Transportation/Federal Highway Administration. 

Metropolitan 

statistical area

Total population

aged 5 years and

over in 2000 that

spoke English

less than well

Percentage of

population in

2000 that spoke

English less than

well

Percentage

change in persons

that spoke English

less than well

1990-2000

Major languages 

spoken by the LEP 

population

Estimated

percentage of LEP

persons aged 16

years and over

using public

transportationa

Los Angeles/

Riverside/Orange 

County, California

2,024,765 12.4 30.0 Spanish, Chinese, 

Vietnamese, and 

Korean

14.5

San Francisco/

Oakland/San Jose, 

California

551,266 7.8 59.0 Spanish, Chinese, 

Vietnamese, and 

Korean

16.3

Chicago/Gary/

Kenosha, Illinois, 

Indiana, Wisconsin

522,238 5.7 75.0 Spanish, Polish, 

Chinese, and Korean

11.9

Austin/San Marcos, 

Texas

67,115 5.4 209.0 Spanish and 

Vietnamese

10.5
Appendix I

Scope and Methodology

Page 60 GAO-06-52 Language Access to Transportation Services

Source: U.S. Census Bureau.

a

All estimated percentages have margins of error not exceeding plus or minus 2.5 percentage points at 

the 95 percent confidence level.

b

At the time of the 2000 Census, transit service in this area was predominantly demand-response. 

Since then, Ozark Regional Transit has begun some limited fixed-route service. 

We conducted semistructured interviews with officials from 20 transit 

agencies and 7 MPOs in these locations who were responsible for some 

facet of providing language access services. We interviewed officials from 

various departments, including operations, marketing, public affairs, 

community relations, training, civil rights, and planning. At smaller 

agencies, we interviewed the general managers as well as other agency 

officials. We chose agencies in each location according to their size and 

characteristics. For example, we interviewed the largest transit agency in 

each location, and where there were several transit agencies operating, we 

then interviewed the next largest agencies. In certain locations, such as the 

Southern California area and the San Francisco Bay Area, we were unable 

to interview all of the agencies in the area due to the large number of 

transit agencies. In these areas, we chose additional agencies on the basis 

of different operating characteristics. For example, in Los Angeles, 

California, we chose to interview the major provider of specialized transit 

services for persons with disabilities, whereas, in the San Francisco Bay 

Area, we chose a suburban bus system to complement the urban systems 

we were obtaining information on. We also interviewed officials from the 

major MPOs in areas we visited. In some cases, an MPO also may provide 

some level of transportation service. For example, the Metropolitan 

Transportation Commission in the San Francisco Bay Area operates the 

region’s 511 transportation information lines. In these instances, we did not 

Raleigh/Durham/

Chapel Hill, North 

Carolina

38,365 3.2 607.0 Spanish and Chinese 3.8

Greensboro/

Winston-Salem/

High Point, North 

Carolina

33,633 2.7 544.0 Spanish and 

Vietnamese

1.1

Fayetteville/

Springdale/

Rogers, Arkansas

9,621 3.1 1,892.0 Spanish and 

Vietnamese

0.0b

(Continued From Previous Page)

Metropolitan 

statistical area

Total population

aged 5 years and

over in 2000 that

spoke English

less than well

Percentage of

population in

2000 that spoke

English less than

well

Percentage

change in persons

that spoke English

less than well

1990-2000

Major languages 

spoken by the LEP 

population

Estimated

percentage of LEP

persons aged 16

years and over

using public

transportationa
Appendix I

Scope and Methodology

Page 61 GAO-06-52 Language Access to Transportation Services

count such agencies as transit agencies, but we included the services they 

provide in the appropriate section of this report. 

We structured the agency interviews on the basis of the elements of the 

Department of Transportation’s (DOT) LEP guidance and the findings of 

previous research and surveys conducted of the language access activities 

of transit agencies. During our interviews, we discussed the types of 

language access activities provided in terms of day-to-day transportation 

services and in the planning and decision-making process; we also 

discussed the costs and effects of these services. We also reviewed 

documents and other information in support of the language access 

services provided by transit agencies and MPOs. 

We also interviewed representatives from 16 community and advocacy 

groups in the areas we visited as well as representatives from national 

advocacy groups, such as the National Council of La Raza, the Center for 

Community Change, and the National Asian Pacific American Legal 

Consortium. We chose groups in the locations we visited on the basis of 

recommendations from these national groups, FTA regional officials, 

transit agency officials, and our own research into the transportation issues 

in these areas. We structured these interviews in order to understand the 

perspectives of these community and advocacy groups with regard to how 

transit agencies and MPOs in the areas are providing access to their 

services to the communities these groups serve, and the effects of these 

services on meeting the needs of LEP communities. The agencies and 

groups we included in our interviews are listed in table 5.
Appendix I

Scope and Methodology

Page 62 GAO-06-52 Language Access to Transportation Services

Table 5: Transit Agencies, MPOs, and Community and Advocacy Groups Interviewed

Metropolitan statistical area Agency or group name Description 

Los Angeles/

Riverside/Orange County, 

California

Los Angeles County Metropolitan 

Transportation Authority

The primary provider of bus, subway, and light-rail transit 

services within the county of Los Angeles.

Access Services A paratransit service provider in the Southern California 

region.

Orange County Transportation 

Authority

The second largest transit provider in Southern California, 

serving Orange County.

Southern California Association of 

Governments

Metropolitan planning organizations (MPO) for the Southern 

California region.

Los Angeles Busrider’s Union An organization in Los Angeles that seeks to promote 

environmentally sustainable public transportation for the entire 

population of Los Angeles.

Alameda Corridor Jobs Coalition A grass roots organization that represents 35 other 

community-based organizations in Los Angeles, whose goal is 

to secure jobs and careers that offer communities living wages 

and ethical benefits.

Center for Community Change A social justice organization. Part of the center is the 

Transportation Equity Project that seeks to advance equity in 

transportation planning and policy. 

Asian Pacific American Legal Center Provides Asian and Pacific Islander and other communities 

with multilingual, culturally sensitive services and legal 

education. 

Legal Aid Foundation of Los Angeles The frontline law firm for low-income people in Los Angeles.

Africans in America Community 

Resource Center

A community group in South Los Angeles that represents 

Africans living in Southern California.

South Asian Network A grassroots, community-based organization dedicated to 

advancing the health, empowerment, and solidarity of persons 

of South Asian origin in Southern California.
Appendix I

Scope and Methodology

Page 63 GAO-06-52 Language Access to Transportation Services

San Francisco/

Oakland/San Jose, California

Municipal Transportation Agency The primary provider of bus and rail transit services in the city 

of San Francisco.

San Francisco Bay Area Rapid Transit 

District

A regional rail transit provider serving the nine-county Bay 

Area.

Alameda-Contra Costa Transit District The primary bus transit provider in the city of Oakland and the 

counties of Alameda and Contra Costa.

Golden Gate Transit The primary bus transit provider in Marin County.

Metropolitan Transportation 

Commission 

MPO for the nine-county Bay Area.

Chinatown Community Development 

Center

The center provides services in six work areas—programs, 

advocacy and organizing, planning, housing development, 

property management, and tenant services—and has done 

some work in the provision of public transportation in its 

community.

Rescue MUNI A transit advocacy organization for the city of San Francisco.

Urban Habitat An advocacy and organizing group that seeks to connect 

environmentalists, social justice advocates, government 

leaders, and the business community. 

Chicago/Gary/

Kenosha, Illinois, Indiana, 

Wisconsin

Chicago Transit Authority Chicago Transit Authority serves Chicago and 40 suburbs with 

its extensive train lines and bus routes.

PACE Suburban Bus The provider of bus service to Chicago's six-county suburbs.

METRA Commuter Rail The provider of commuter rail service between the downtown 

Chicago business district and the counties of Cook, DuPage, 

Lake, Will, McHenry, and Kane.

Regional Transportation Authority The financial oversight and regional planning body for the 

three public transit operators in northeastern Illinois: the 

Chicago Transit Authority, METRA commuter rail, and PACE 

suburban bus.

Chicago Area Transportation Study MPO for the northeastern Illinois region.

Center for Neighborhood Technology An advocacy group based in Chicago with a mission to invent 

and implement new tools and methods that create livable 

urban communities for everyone.

Chicago Chinese Community Center The primary community provider of services to Chicago 

Chinatown residents.

(Continued From Previous Page)

Metropolitan statistical area Agency or group name Description 
Appendix I

Scope and Methodology

Page 64 GAO-06-52 Language Access to Transportation Services

Source: GAO. 

We also conducted interviews with officials within the Texas, California, 

and North Carolina departments of transportation and conducted 

additional Internet research of state departments of transportation, to 

determine how these agencies were involved in providing or monitoring 

language access. Furthermore, we requested that the Community 

Austin/San Marcos, Texas Capital Metro The primary provider of bus transit services in the city of 

Austin.

Capital Area Rural Transportation 

System

The provider of bus transit service in the counties of Bastrop, 

Blanco, Burnet, Caldwell, Fayette, Hays, Lee, Travis, and 

Williamson.

Capital Area Metropolitan Planning 

Organization

MPO for Williamson, Travis, and Hays counties. 

Just Transportation Alliances An organization that seeks to organize people with disabilities, 

seniors, low-income individuals, and others for equitable 

transportation through state and local alliances.

Poder (Bus Rider’s Union) A grass-roots organization that advocates for the Hispanic 

communities in Austin.

Fayetteville/

Springdale/

Rogers, Arkansas

Razorback Transit The primary provider of bus transit services in the city of 

Fayetteville, with the vast majority of its ridership consisting of 

students and faculty at the University of Arkansas. 

Ozark Regional Transit, a public transit 

system managed by First Transit

The primary provider of bus transit and demand-response 

transit services, serving both the urban and rural areas of 

Benton, Carroll, Madison, and Washington counties.

Northwest Arkansas Regional 

Planning Commission

The designated MPO for transportation in northwest 

Arkansas.

Rogers Community Support Center A community center in Rogers, Arkansas, that provides 

information and assistance to members of the community.

Raleigh/Durham/Chapel Hill, 

North Carolina; and 

Greensboro/

Winston-Salem/

High Point, North Carolina 

Capital Area Transit The provider of bus transit services in the city of Raleigh.

Durham Area Transit Authority The provider of bus and paratransit services, serving all parts 

of Durham, including Research Triangle Park. 

Chapel Hill Transit The provider of bus transit services throughout the Chapel Hill, 

Carrboro, and University of North Carolina community.

Triangle Transit Authority The provider of regional bus transit services in Research 

Triangle Park, connecting to the cities of Raleigh and Chapel 

Hill.

Greensboro Transit Authority The primary provider of bus transit services in the city of 

Greensboro.

Capital Area MPO MPO for the Raleigh/Durham metropolitan area.

Durham-Chapel Hill MPO MPO for the western part of the Research Triangle Area.

El Centro Hispano A nonprofit, community-based organization based in Durham 

dedicated to Latino empowerment through education and 

leadership development.

(Continued From Previous Page)

Metropolitan statistical area Agency or group name Description 
Appendix I

Scope and Methodology

Page 65 GAO-06-52 Language Access to Transportation Services

Transportation Association of America, which operates a list-serve of Job 

Access and Reverse Commute grantees, send a query requesting that any 

grantees involved in providing language access services under those grants 

provide information on the types of services they offer. We received two 

responses from this query.

We complemented these case studies and interviews with findings from a 

survey of transit agencies across the country and surveys and focus groups 

with LEP persons in New Jersey conducted for the New Jersey Department 

of Transportation.2

 We reviewed the methodology of this study and found it 

to be sufficiently reliable for the purposes of our report. However, the 

results of the surveys and focus groups reported in this study cannot be 

generalized to the full universe of transit agencies or LEP persons. Rather, 

we used the findings in this study to provide additional information on the 

types of strategies that agencies use as well as the types of challenges that 

LEP populations face. 

We synthesized the information we collected from the site visits, structured 

interviews, and the New Jersey study. We analyzed this information to 

identify major themes, commonalities, and differences in the level of 

language access provided by transit agencies and MPOs. We observed that 

almost all transit agencies and MPOs we visited provided some level of 

language access services, although levels varied across agencies and 

locations. Because these findings are based on a nonprobability sample of 

case studies and a survey of 32 transit agencies, they cannot be generalized 

to the full universe of transit agencies or MPOs across the country.3

 These 

case studies are meant to highlight the variety of different strategies 

agencies may use to improve communication with LEP persons, as well as 

key themes that emerge under various circumstances. 

To understand how DOT assists local agencies in providing language 

access services, we interviewed officials at the Offices of Civil Rights in 

FTA and the Federal Highway Administration (FHWA), representatives 

from the National Transit Institute and the National Highway Institute, and 

DOT regional officials. During our interviews, we identified and discussed 

various resources available that may include information on language 

2

Liu, Mobility Information Needs of LEP Travelers.

3

Results from nonprobability samples cannot be used to make inferences about a population 

because in a nonprobability sample, some elements of the population being studied have no 

chance or an unknown chance of being selected as part of the sample.
Appendix I

Scope and Methodology

Page 66 GAO-06-52 Language Access to Transportation Services

access activities, including training curricula and workshops. We 

interviewed officials from FHWA offices in California, Maryland, and New 

Jersey regarding some of their LEP activities, such as hosting workshops at 

annual conferences and other assistance they have provided grantees. We 

reviewed Executive Order 13166, the Department of Justice’s (DOJ) and 

DOT’s draft LEP guidance, other federal laws and regulations, and research 

related to providing access to services to LEP populations. We requested 

copies of identified trainings and reviewed them. We also identified and 

reviewed other various DOT resources and other federal resources to 

determine whether language access issues were addressed, including

http://www.lep.gov and peer-exchange programs maintained by FTA and 

FHWA. 

To understand the extent to which local agencies are accessing DOT’s 

resources, we discussed with local agency officials their awareness and 

implementation of DOT’s LEP guidance. We also discussed with these 

officials whether the agency has accessed DOT’s resources and, if so, had 

the resources been helpful in the provision of language access activities. In 

addition, we reviewed Web statistics for materials available on the Internet 

for additional information on how often those materials were accessed.

To document how FTA and FHWA monitor transit agencies’ and MPOs’ 

provision of language access services for LEP populations, we interviewed 

officials from the FTA Office of Civil Rights; the FTA Office of Program 

Management; and FHWA’s Office of Planning, Environment and Realty. We 

also interviewed FTA regional representatives from Arkansas, California, 

Illinois, North Carolina, and Texas. We reviewed oversight documents 

pertaining to Title VI compliance reviews, triennial reviews, and planning 

certification reviews to determine how language access is considered by 

these reviews (i.e., specific questions regarding language access activities) 

and to what degree these reviews incorporate DOT’s LEP guidance. In 

addition, we collected available data on any findings from these reviews to 

analyze the extent to which norms have been developed for reviewers to 

determine whether deficiencies are found and reported. Furthermore, we 

reviewed the status and outcomes of LEP complaints.

We conducted our work from February 2005 through October 2005 in 

accordance with generally accepted government auditing standards.
Page 67 GAO-06-52 Language Access to Transportation Services

Appendix II

Resources Available on Providing Language 

Access for Transportation Services ApendxiI

Provision of Language 

Access Services

• Executive Order 13166 Improving Access to Services for Persons with 

Limited English Proficiency: Executive Order 13166 was signed by 

President Clinton in 2000. It clarifies federal agencies and their grant 

recipients’ responsibilities under Title VI, to make their services 

accessible to LEP populations.

http://usdoj.gov/crt/cor/Pubs/eolep.htm 

• DOT Guidance to Recipients on Special Language Services to Limited 

English Proficient (LEP) Beneficiaries: DOT’s guidance was issued in 

2001. It discusses strategies for providing services to LEP persons and 

outlines a five-step framework to an effective language access program 

as well as innovative practices.

http://usdoj.gov/crt/cor/lep/dotlep.htm 

• Federal Interagency Working Group on Limited-English Proficiency: 

The http://www.lep.gov Web site, maintained by DOJ, serves as a 

clearinghouse, providing and linking information, tools, and technical 

assistance regarding LEP and language services for federal agencies, 

recipients of federal funds, and users of federal programs and federally 

assisted programs. The Web site includes a self-assessment tool and an 

overview of how to develop a language assistance plan with 

performance measures. There is also a video available from the Web site 

on LEP access issues that could be used in training for customer service 

personnel at transit agencies. 

http://www.lep.gov

• FTA Title VI Web site: FTA’s Title VI Web site provides information and 

resources on Title VI, including links to Executive Order 13166, DOT’s 

LEP guidance, and http://www.lep.gov.

http://fta.dot.gov/16241_ENG_HTML.htm

• FHWA Office of Civil Rights Web site: FHWA’s Office of Civil Rights Web 

site provides links to Title VI, Executive Order 13166, and DOT’s LEP 

guidance.

http://fhwa.dot.gov/civilrights/nondis.htm

• Workshop entitled How to Identify Limited English Proficient (LEP) 

Populations in Your Locality: This workshop was given by FHWA at the 

American Association of State Highway and Transportation Official’s 

2004 Civil Rights Conference. The workshop provides information on 

the LEP executive order, DOT’s LEP guidance, and specific information 
Appendix II

Resources Available on Providing Language 

Access for Transportation Services

Page 68 GAO-06-52 Language Access to Transportation Services

about what resources can be used to identify LEP populations.

http://fhwa.dot.gov/civilrights/confworkshops04.htm

• FTA’s Innovative Practices to Increase Ridership: The Web site serves 

as a central information resource on innovative strategies on various 

topics. Innovative practices are submitted by transit organizations, 

reviewed by FTA, and are then made available for other transit 

organizations to search records, review innovations, and potentially 

implement similar programs. Innovative practices regarding language 

access services are available.

http://ftawebprod.fta.dot.gov/bpir/

• FTA and FHWA’s Transportation Planning Capacity Building 

Program: Users can search various topics to find out if like sized or any 

type of agency has posted any helpful information on those topics. 

Information regarding language access services is available.

http://planning.dot.gov/

• National Transit Institute course entitled Public Involvement in 

Transportation Decision-Making: This course includes is a section on 

ensuring that nontraditional participants, that is, minority, low-income, 

and LEP populations are included in the public involvement process 

that is associated with transportation planning. 

http://ntionline.com/

• National Highway Institute course entitled Fundamentals of Title 

VI/Environmental Justice and Public Involvement in the Transportation 

Decision-Making Process: These courses include a discussion on 

language access issues in the planning process.

http://nhi.fhwa.dot.gov/

• Caltrans Title VI Web site: Caltrans’ Title VI Web site includes 

information and resources on Title VI and links to FHWA’s Office of Civil 

Rights training resources, the Web site for the Civil Rights Division of 

DOJ, and lep.gov. In addition, there are three training videos available 

for free, one specifically on the language assistance for LEP persons.

http://dot.ca.gov/hq/bep/title_vi/t6_index.htm

• Mobility Information Needs of Limited English Proficiency (LEP) 

Travelers in New Jersey: A report written by Dr. Rongfang (Rachel) Liu, 

prepared for the New Jersey Department of Transportation/Federal 
Appendix II

Resources Available on Providing Language 

Access for Transportation Services

Page 69 GAO-06-52 Language Access to Transportation Services

Highway Administration. December 2004. 

http://transportation.njit.edu/nctip/final_report/LEP.htm 

Community 

Involvement in 

Transportation 

Planning

• The Metropolitan Transportation Planning Process: Key Issues: A 

Briefing Notebook for Transportation Decisionmakers, Officials, and 

Staff: Published by the Transportation Planning Capacity Building 

Program, this document has information on public participation, 

including sections on Title VI and Environmental Justice. 

http://planning.dot.gov/documents/BriefingBook/BBook.htm 

• Public Involvement Techniques for Transportation Decision-Making: 

Published by FHWA, this document discusses public involvement 

techniques for transportation decision making for ethnic, minority, and 

low-income groups, such as including community groups that may 

provide access to individuals and can serve as forums for participation.

http://fhwa.dot.gov/reports/pittd/contents.htm 

• Final report September 2002: Title VI Challenge Grant from the 

Federal Transit Administration to the National Capital Region 

Transportation Planning Board: This report outlines recommendations 

for how to include communities not typically involved in the 

transportation planning process. Included in the report is a discussion 

concerning LEP issues. 

http://planning.dot.gov/Documents/EnvJustice/EJFinalReport.htm 

• Innovations in Public Involvement for Transportation Planning: This 

document discusses techniques for getting the public involved in 

transportation planning, such as using surveys with questions in 

languages other than English and accessible to persons with disabilities.

http://ntl.bts.gov/DOCS/trans.html 
Page 70 GAO-06-52 Language Access to Transportation Services

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contact Kate Siggerud (202) 512-2834 or siggerudk@gao.gov

Staff 

Acknowledgments

In addition to the individual named above, Rita Grieco, Assistant Director; 

Michelle Dresben; Edda Emmanuelli-Perez; Harriet Ganson; Joel 

Grossman; Diane Harper; Charlotte Kea; Grant Mallie; John M. Miller; Sara 

Ann Moessbauer; Marisela Perez; Ryan Vaughan; Andrew Von Ah; Mindi 

Weisenbloom; and Alwynne Wilbur made key contributions to this report. 

(542052)
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